The U.S. IRS and Treasury have issued final regulations providing Guidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income (TD 9959). The regulations are scheduled to be formally published in the Federal Register on 4 January 2022 and will be effective 60 days after publication.
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SUMMARY: This document contains final regulations relating to the foreign tax credit, including the disallowance of a credit or deduction for foreign income taxes with res…