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Final and proposed regulations released to Federal Register: Foreign tax credit (text of regulations)

Foreign tax credit

The U.S. Treasury Department and IRS today officially released for publication in the Federal Register final regulations (T.D. 9922) and proposed regulations (REG-101657-20) implementing foreign tax credit measures.

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  • Read the final regulations [PDF 582 KB] (78 pages as published in the Federal Register on November 12, 2020)
  • Read the proposed regulations [PDF 641 KB] (79 pages as published in the Federal Register on November 12, 2020)

Comparisons against prior IRS versions of regulations

The IRS on September 29, 2020, posted to its website versions of these final and proposed regulations that contain the following statement:

This document is in the process of being submitted to the Office of the Federal Register (OFR) for publication and will be pending placement on public display at the OFR and publication in the Federal Register. The version of the … regulation 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 KPMG report providing initial impressions and observations (based on the versions of the final and proposed regulations posted by the IRS in September 2020): TaxNewsFlash [PDF 378 KB]

These are unofficial documents produced by KPMG that are intended to show what changes, if any, were made to the regulations prior to being released to the Federal Register for publication. These KPMG 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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