U.S. IRS Provides Temporary Relief for Foreign Tax Credit under Sections 901 and 903

The U.S. IRS has issued Notice 2023-55, Temporary Relief Under Sections 901 and 903 of the Internal Revenue Code.

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Part III - Administrative, Procedural, and Miscellaneous

Temporary Relief Under Sections 901 and 903 of the Internal Revenue Code

Notice 2023-55

SECTION 1. PURPOSE

This notice announces temporary relief for taxpayers in determining whether a foreign tax is eligible for a foreign tax credit under §§ 901 and 903 of the Internal Revenue Code (Code). This temporary rel…