On 21 April 2017, the U.S. IRS published an international practice unit: Overview - Expense Allocation/Apportionment in Calculation of the IRC 904 FTC Limitation. The practice unit provides a general overview, relevant key factors, detailed explanation, and examples for calculating the limitation for the Foreign Tax Credit (FTC) a taxpayer can utilize each year considering the allocation and apportionment of expenses.
International practice units are developed by the Large Business and Inte…