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TAX & TECHNOLOGY BLOG

Highlights of the Recently Issued Final and Proposed Foreign Tax Credit Regulations

On December 2 2019, the Treasury and IRS issued both final and newly proposed foreign tax credit regulations. The regulations were a long time coming; the original 2018 proposed regulations were issued on November 28, 2018.  While largely consistent with the 2018 proposed regulations – including the multi-step process contained in Prop. Reg. § 1.861-13 – there are some noteworthy changes that taxpayers should be aware of within the newly issued regulations.

KNOWLEDGE

Section 382(h) Proposed Regs Throw Taxpayers a Curveball

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RESULTS

“Automating the provision process has saved Sonepar USA’s tax team upwards of 120 hours (in aggregate) for the 2017 tax-year alone. The GTM team facilitated a smooth transition from our manual Excel approach to take immediate advantage of ONESOURCE Tax Provision (OTP) software. Our new provision process has been recognized positively up to the senior finance executives, raising the visibility and value of our tax department’s contributions to the bottom line.”

 

~ Nick Vanderlyke, Senior Manager, Income Tax, Sonepar USA

 

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NEWS

Section 382(h) Proposed Regs Throw Taxpayers a Curveball

December 04, 2019

The U.S. Treasury and IRS issued proposed regulations under IRC Section 382(h) pertaining to the interaction between built-in gains or losses with Section 382 limitations. GTM’s James P. Swanick, CPA, and Michael J. Tighe, CPA, offer their analysis in the latest issue of the Pennsylvania CPA Journal.

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