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US Department of the Treasury and the Internal Revenue Service (IRS) issued final regulations that deny a foreign tax credit for certain foreign withholding taxes and other taxes
On January 4, 2022, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final regulations (Final Regulations) that deny a foreign tax credit (FTC)...
On December 28, 2021, the Treasury Department and the IRS issued another tranche of final foreign tax credit (FTC) regulations, which were officially published in the Federal Register on January 4, 2022.
Our International Tax Group delves into the attribution requirement (née jurisdictional nexus requirement) of the final foreign tax credit regulations and finds that taxpayers will...