IRS Releases Practice Unit on Foreign and Domestic Loss Impacts on the Foreign Tax Credit

On 1 March 2017, the U.S. IRS published an international practice unit: Summary of Foreign and Domestic Loss Impacts on the Foreign Tax Credit. The practice unit provides a general overview as well as detailed explanations of the rules regarding loss allocation, recharacterization, and recapture for:

• Overall Foreign Loss (OFL);
• Separate Limitation Loss (SLL); and
• Overall Domestic Loss (ODL).

International practice units are developed by the Large Business and International Division of the…