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Guidance Related to the Allocation and Apportionment of Deductions and Foreign Taxes, Financial Services Income, Foreign Tax Redeterminations, Foreign Tax Credit Disallowance Under Section 965(g), and Consolidated Groups (REG-105495-19)

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U.S. Chamber of Commerce filings
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U.S. Chamber of Commerce filed 1 comment on this docket between Feb 14, 2020 and Feb 14, 2020. 1 other organizations filed here. The comment window closed 2269d ago.

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Feb 14, 2020· Comment from Caroline Harris, U.S. Chamber of Commerce· IRS-2019-0055-0010

Please find attached the U.S. Chamber's comments on REG-105495-19: guidance related to the allocation and apportionment of deductions and foreign taxes, the definition of financial services income, foreign tax redeterminations under section 905(c), the disallowance of certain foreign tax credits under section 965(g), and the application of the foreign tax credit limitation to consolidated groups, as published in the Federal Register on December 17, 2019.

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Abstract

This document contains proposed regulations that 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.

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