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KPMG report: Analysis of final and proposed foreign tax credit regulations

Analysis of final and proposed foreign tax credit

Final regulations (T.D. 9882) relating to sections 78, 864, 901, 904, and 960 and proposed regulations (REG-105495-19) relating to foreign tax credits were published in the Federal Register earlier this week, on December 17, 2019.


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The U.S. Treasury Department and IRS on December 2, 2019, issued versions of these regulations in advance of their release to the Federal Register.

  • The final regulations finalize regulations that were proposed in November 2018 relating to sections 78, 864, 901, 904, and 960, as amended by the 2017 U.S. tax law (Pub. L. No. 115-97, enacted December 22, 2017, and often referred to as the “Tax Cuts and Jobs Act” or “TCJA”). 
  • The proposed regulations provide additional guidance relevant to foreign tax credits—including guidance with respect to the allocation and apportionment of research and experimentation and stewardship expenses, foreign tax redeterminations under section 905(c), and the allocation and apportionment of foreign income taxes to categories of income.

Read a December 2019 report [PDF 763 KB] (42 pages) prepared by KPMG LLP providing initial analysis and observations about the final regulations and the 2019 proposed regulations: KPMG report: Analysis of final and proposed foreign tax credit regulations

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