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Final regulations: Partnership allocations of foreign income taxes to partners

Partnership allocations of foreign income taxes

The U.S. Treasury Department and IRS today released for publication in the Federal Register final regulations (T.D. 9871) concerning the allocation by a partnership of foreign income taxes to partners. Specifically, the regulations concern the rules for allocations of “creditable foreign tax expenditures” (CFTEs).


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Today’s final regulations [PDF 340 KB] adopt and finalize regulations that were proposed in February 2016 but with certain minor clarifications. Corresponding temporary regulations (February 2016) are also removed. Read a KPMG report of initial impressions and observations about the 2016 regulations: TaxNewsFlash

The final regulations are scheduled to be published in the Federal Register on July 24, 2019.

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