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Final regulations: Foreign tax credit, section 901(m) and “covered asset acquisitions”

Foreign tax credit, section 901(m) and “covered asset

The U.S. Treasury Department and IRS today released for publication in the Federal Register final regulations under section 901(m) and the rules that limit a taxpayer’s ability to claim foreign tax credit associated with a “covered asset acquisition.”


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A covered asset acquisition is, in general, an acquisition transaction that results in the creation of additional asset basis for U.S. tax purposes without a corresponding increase in asset basis for foreign tax purposes.

The final regulations [PDF 392 KB] (88 pages) adopt regulations that were proposed in 2016, with certain revisions.

The purpose of this report is to provide text of the final regulations.

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