Eversheds Sutherland Tax Reform Law Blog
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Treasury and IRS Release Final and Proposed Foreign Tax Credit Regulations

On September 29, the Department of the Treasury and the Internal Revenue Service released final and proposed regulations that provide guidance with respect to the calculation of foreign tax credits. The final regulations address a variety of computational issues, such as the allocation and apportionment of deductions under sections 861 through 865, the allocation of apportionment of...