Guidance: Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income (REG–101657–20)

1 organizations filed 1 public comment on Guidance: Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income (REG–101657–20), at the Internal Revenue Service. The comment window closed 1993d ago.

Abstract

This document contains proposed regulations relating to the foreign tax credit, including guidance on the disallowance of a credit or deduction for foreign income taxes with respect to dividends eligible for a dividends-received deduction; the allocation and apportionment of interest expense, foreign income tax expense, and certain deductions of life insurance companies; the definition of a foreign income tax and a tax in lieu of an income tax; transition rules relating to the impact on loss accounts of net operating loss carrybacks allowed by reason of the Coronavirus Aid, Relief, and Economic Security Act; the definition of foreign branch category and financial services income; and the time at which foreign taxes accrue and can be claimed as a credit.

Commenters (1)

• U.S. Chamber of Commerce

  1 filing · confidence 97%