IRS Prop. Reg.: Official Publication Date for Proposed Foreign Tax Credit Guidance (IRC §904)

IRS officially sets December 17 as the Federal Register publication date for proposed regulations that would provide guidance relating to the foreign tax credit. The proposed regulations cover: (1) the allocation and apportionment of deductions under tax code Section 861 through Section 865, including new rules on the allocation and apportionment of R&E expenditures and certain deductions of life insurance companies; (2) the definition of financial services income under Section 904(d)(2)(D); (3) the allocation and apportionment of creditable foreign taxes; (4) the interaction of the branch loss and dual consolidated loss recapture rules with Section ...