The U.S. IRS and Treasury have issued a notice of proposed rulemaking for consultation on Guidance Related to the Foreign Tax Credit (REG-112096-22). This includes proposed regulations relating to the foreign tax credit, including regulations addressing the following issues: (1) the definition of a reattribution asset for purposes of allocating and apportioning foreign income taxes; (2) the application of the cost recovery requirement; and (3) the application of the source-based attribution …