Regulations relating to foreign tax credit released to Federal Register

Regulations relating to foreign tax credit

The U.S. Treasury Department and IRS today released for publication in the Federal Register final regulations (T.D. 9882) and proposed regulations (REG-105495-19) relating to the determination of foreign tax credit.


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Read the versions of the regulations released today for publication in the Federal Register:

  • The final regulations [PDF 717 KB] (102 pages as published in the Federal Register) finalize regulations that were proposed in December 2018. 
  • The proposed regulations [PDF 545 KB] (57 pages as published in the Federal Register) provide additional guidance relevant to foreign tax credits, including with respect to the allocation and apportionment of research and experimentation (R&E) and stewardship expenses, foreign tax redeterminations under section 905(c), and base and timing differences.

Read TaxNewsFlash providing initial impressions and observations about these foreign tax credit regulations (this report is based on versions of the regulations released in advance by the IRS on December 2, 2019).

Advance versions of final and proposed regulations

The IRS and Treasury released a version of these final and proposed regulations on December 2, 2019. Those versions of the regulations were posted on the IRS website and include the following statement:

This document has been submitted to the Office of the Federal Register (OFR) for publication. The version of the [final or proposed] rule released today may vary slightly from the published document if minor editorial changes are made during the OFR review process. The document published in the Federal Register will be the official document.

These are unofficial documents produced by KPMG that are intended to show what changes, if any, have been made to the final regulations and proposed regulations prior to release to the Federal Register for publication. These documents have not been reviewed for accuracy.

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

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