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.
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.
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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