- Recently released proposed regulations address questions and comments raised on the previously issued foreign tax credits regulations.
- The proposed regulations ease some requirements for claiming the foreign tax credit.
The U.S Department of the Treasury and the IRS on Nov. 22 issued proposed foreign tax credit regulations addressing questions and comments with respect to final regulations that were published on Jan. 4. The final regulations narrow the scope of foreign taxes eligible for a credit or deduction against U.S. tax liabilities. Two sets of technical corrections to the final regulations were published on July 27. The technical corrections provided limited clarification regarding the definition of creditable foreign taxes. They did not address more substantive questions and comments that taxpayers and practitioners raised after publication of the final regulations. The latest proposed regulations resolve some, but not all, of the questions and comments.