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.
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.
- Read a computer-generated document (final regulations) [PDF 1.3 MB] that compares the version of the final regulations submitted today to the Federal Register against the version previously released by the IRS on December 2, 2019.
- Read a computer-generated document (proposed regulations) [PDF 756 KB] that compares the version of the proposed regulations submitted today to the Federal Register against the version previously released by the IRS on December 2, 2019.
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.
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