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Proposed foreign tax credit regulations released to Federal Register

Foreign tax credit, U.S. proposed regulations

The U.S. Treasury Department and IRS this afternoon released for publication in the Federal Register proposed regulations (REG-105600-18) relating to the foreign tax credit measures under the new U.S. tax law.


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Treasury and the IRS have requested comments on the proposed regulations. Comments and requests for a public hearing must be received by a date that is 60 days after the date when these regulations will appear in the Federal Register, as scheduled for December 7, 2018.

Advance version released November 28

The IRS on November 28, 2018, released a version of these proposed regulations, and with that release, noted that the proposed regulations had been submitted to the Federal Register for publication; that such publication was pending; and that the version of the proposed regulations released on November 28 “… may vary slightly from the published document if minor editorial changes are made during the [Federal Register] review process. The document published in the Federal Register will be the official document.”

Read a computer-generated document [PDF 6.2 MB] (an unofficial document produced by KPMG) that compares the 312-page version of the proposed regulations that was submitted to the Federal Register for publication (released on November 28, 2018), with the 285-page version of the proposed regulations released for publication in the Federal Register (released on December 4, 2018).

This document is intended to show what changes, if any, have been made to the proposed regulations prior to publication in the Federal Register. It has not been reviewed for accuracy.  

Legend: Omitted text is shown as stricken, new text is indicated by the blue highlight, and replaced text is highlighted in orange.

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