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).
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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