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IRS issues minor corrections to proposed rules on foreign tax credits

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Tax Hot Topics newsletterThe IRS made four corrections to proposed regulations (REG-105600-18) related to the foreign tax credit regime on March 6. See our prior coverage on the proposed regulations here.

The corrections were mostly minor and sought to clarify potentially misleading errors and phrasings in provisions issued under Sections 861, 904, and 965.  The most notable change was to Section 1.904(f)–12, which incorrectly stated the effective date of certain provisions. The correction replaced the language ‘‘beginning after (Dec.) 31, 2018.’’ to read ‘‘beginning after (Dec.) 31, 2017.’’ The IRS also corrected language addressing the application of carrybacks and carryforwards of separate limitation losses in cases where taxpayers elect not to apply net operating loss deductions under Section 965(n).

Contacts:
David Sites
Partner
Washington National Tax Office 
T +1 202 861 4104

David Zaiken
Managing Director
Washington National Tax Office 
T  +1 202 521 1543

Cory Perry
Senior Manager
Washington National Tax Office 
T +1 202 521 1509

Mike Del Medico
Manager
Washington National Tax Office 
T +1 202 521 1522

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