Final and Proposed regulations issued by the U.S. IRS and Treasury on the determination of foreign tax credits were published in the Federal Register on 17 December 2019.
Final regulations TD 9882 provide foreign tax credit guidance related to the Tax Cuts and Jobs Act, overall foreign loss recapture, and foreign tax redeterminations. As summarized in the regulations, this document contains final regulations that provide guidance relating to the determination of the foreign tax credit unde…