KPMG report: Initial analysis of final regulations concerning foreign tax credit

A KPMG report provides a discussion and initial analysis of the final regulations

A KPMG report provides a discussion and initial analysis of the final regulations

Final regulations released in late December 2021 and published yesterday (January 4, 2022) in the Federal Register relate primarily to the determination of the foreign tax credit (FTC) and the allocation and apportionment of deductions (including foreign income taxes) in determining the FTC limitation.

This final regulation package marks the fourth significant revision of the FTC regulations since enactment of the 2017 U.S. tax law (Pub. L. No. 115-97, enacted December 22, 2017, and often referred to as the “Tax Cuts and Jobs Act” or “TCJA”).

These final regulations substantially overhaul longstanding FTC regulations involving the determination of creditable foreign income taxes.

The final regulations finalize most aspects of regulations proposed in September 2020, but with certain modifications to address the comments received with regard to those proposed regulations. 

Read a January 2022 report [PDF 1.5 MB] (43 pages) prepared by KPMG LLP that provides a discussion and initial analysis of the final regulations.

 

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