IRS Prop. Reg.: Foreign Tax Credit Guidance Corrected (IRC §904)

Corrections to proposed regulations that would provide guidance relating to the allocation and apportionment of deductions and creditable foreign taxes, the definition of financial services income, foreign tax redeterminations, availability of foreign tax credits under the transition tax, and the application of the foreign tax credit limitation to consolidated groups, issued by the IRS May 14. The corrections update inaccurate I.R.C. reference in the proposed regulations under tax code Section 861 and Section 960. The preamble is also updated to reflect a change in the applicability date language. [REG-105495-19, RIN 1545-BP21, 85 Fed. Reg. __ (May 15, ...