Final regulations on foreign tax credit, clarification of FDII; OIRA review completed
OIRA completed its review of final regulations concerning foreign tax credit provisions enacted by TCJA
OIRA completed its review of final regulations concerning foreign tax credit provisions
OMB’s Office of Information and Regulatory Affairs (OIRA) reported it completed its review of final regulations concerning the foreign tax credit provisions enacted by the 2017 U.S. tax law (Pub. L. No. 115-97) or the law that is commonly referred to as the “Tax Cuts and Jobs Act” (TCJA).
OIRA’s review was completed on December 10, 2021, and the final regulations are listed on the OIRA website as:
- RIN: 1545-BP70: Guidance related to the foreign tax credit, clarification of foreign-derived intangible income [TCJA]
A brief description provided by OIRA is as follows:
These regulations provide guidance related to the foreign tax credit, including guidance with respect to expense allocation, legal liability for foreign tax, transition rules relating to the impact on loss accounts of net operating loss carrybacks, definition of a foreign income tax, and when foreign taxes accrue and may be claimed as credit. The regulations also provide guidance clarifying rules relating to foreign-derived intangible income.
The regulations were proposed in September 2020. Read TaxNewsFlash
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