The U.S. IRS and Treasury have issued correcting amendments to the final and temporary regulations (TD 9922) that were published 12 November 2020, providing guidance related to the allocation and apportionment of deductions and foreign taxes, foreign tax redeterminations, foreign tax credit disallowance under section 965(g), consolidated groups, hybrid arrangements, and certain payments under section 951A. The correcting amendments were published in the Federal Register on 1 October 2021 an…