Please find attached the Chambers comments on REG-101657-20, 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; the time at which foreign taxes accrue and can be claimed as a credit as well as proposed regulations clarifying rules relating to foreign-derived intangible income, as published in the Federal Register on November 12, 2020.
Guidance: Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income (REG–101657–20)
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U.S. Chamber of Commerce filed 1 comment on this docket between Feb 8, 2021 and Feb 8, 2021. 0 other organizations filed here. The comment window closed 1993d ago.
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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.
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