What’s In: Treasury Tweaks Final Foreign Tax Credit Rules

Treasury on Tuesday took its first stab at addressing concerns raised about final foreign tax credit rules released last December.

Officials have previously said they wouldn’t rewrite or delay the final rules but would instead offer some clarifications. Treasury on Tuesday released a set of technical changes aimed at alleviating some companies’ fears that a key “cost recovery” provision of the rules was too restrictive and could leave some of their foreign taxes ineligible for the credit, making them pay taxes twice on the same income. (Read the corrections here and here.)

But technical corrections can only clarify the ...