Course description:
Treasury and the IRS released proposed foreign tax credit regulations on November 18, which potentially may be the last major change to the creditability regulations for some time. The regulations address the cost recovery requirement, the attribution requirement for withholding tax on royalty payments, and the definition of a reattribution asset for purposes of allocating and apportioning foreign taxes. On this webcast, we will discuss how taxpayers may rely on the proposed provisions and how these regulations insert some much-needed flexibility into the FTC regime.