IRS Releases Proposed Foreign Tax Credit Regulations
On November 28, the IRS released proposed regulations (REG-105600-18) concerning the treatment of foreign tax credits and related issues taking into account the changes made by under the Tax Cuts and Jobs Act (TCJA). Foreign tax provisions under the TCJA modified the method for calculating taxable income for purposes of the foreign tax credit limitation; added two additional foreign tax credit limitation categories, for amounts includible under the new Global Intangible Low-Taxed Income (GILTI) provisions of the TCJA and foreign branch income; and repealed the pooling concept for computing deemed-paid foreign tax credits on dividends. These proposed regulations are proposed to apply to taxable years beginning after 2017. Written or electronic comments and requests for a public hearing are requested, and must be received within 60 days after the regulations are published in the Federal Register.
Read more: IRS Issues Proposed Regulations on Foreign Tax Credits
Read the Proposed Regulations: REG-105600-18