If I(RS) Could Turn Back Time: Notice 2023-55 Offers FTC Creditability Rules Relief

Episode 08-2023 | With tax return preparation season already in full swing, taxpayers received some unexpected (albeit temporary) relief from the foreign tax creditability requirements introduced by the 2022 final foreign tax credit regulations for tax years ending on or before December 31, 2023.

While this is a welcome move by the government, it comes with many questions. What relief does Notice 2023-55 provide and what are the limitations to this relief? How does the notice treat foreign income taxes as compared to “in lieu of” taxes, such as withholding taxes? What are some of the questions that taxpayers are dealing with in interpreting the notice? Why now, after we had already lived with the new foreign tax creditability requirements for over a year and a half? And what does the future hold for the foreign tax creditability rules?

Join us as our podcast co-hosts Gary Scanlon and Kristen Gamboa are joined by Seth Green and Quyen Huynh to explore these issues and more.