Guidance Related to the Allocation and Apportionment of Deductions and Foreign Taxes, Foreign Tax Redeterminations, Foreign Tax Credit Disallowance Under Section 965(g), Consolidated Groups, Hybrid Arrangements and Certain Payments Under Section 951A
other · IRS · Rule · Published 2020-11-12 · Effective 2021-01-11 · 85 FR 71998
Document
Document number
2020-21819
Federal Register citation
85 FR 71998
CFR reference
26 CFR 1
Type
Rule
Action
Final and temporary regulations and removal of temporary regulations.
Category
other
Sub-agency
IRS
Publication date
2020-11-12
Effective date
2021-01-11
Treasury docket
TD 9922
Abstract
This document contains final regulations that provide guidance relating to the allocation and apportionment of deductions and creditable foreign taxes, the definition of financial services income, foreign tax redeterminations, availability of foreign tax credits under the transition tax, the application of the foreign tax credit limitation to consolidated groups, adjustments to hybrid deduction accounts to take into account certain inclusions in income by a United States shareholder, conduit financing arrangements involving hybrid instruments, and the treatment of certain payments under the global intangible low-taxed income provisions.