December 05, 2019
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.