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Guidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income

tax-irs · IRS · Rule · Published 2022-01-04 · Effective 2022-03-07 · 87 FR 276

Document

Document number
2021-27887
Federal Register citation
87 FR 276
CFR reference
26 CFR 1
Type
Rule
Action
Final regulations.
Category
tax-irs
Sub-agency
IRS
Publication date
2022-01-04
Effective date
2022-03-07
Treasury docket
TD 9959

Abstract

This document contains final regulations relating to the foreign tax credit, including the disallowance of a credit or deduction for foreign income taxes with respect to dividends eligible for a dividends-received deduction; the allocation and apportionment of interest expense, foreign income tax expense, and certain deductions of life insurance companies; the definition of a foreign income tax and a tax in lieu of an income tax; the definition of foreign branch category income; and the time at which foreign taxes accrue and can be claimed as a credit. This document also contains final regulations clarifying rules relating to foreign-derived intangible income (FDII). The final regulations affect taxpayers that claim credits or deductions for foreign income taxes, or that claim a deduction for FDII.

Source

Authoritative
Federal Register document
Machine
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