In the quest to address continued taxpayer concerns regarding the final foreign tax credit (FTC) regulations published in January a year ago as well as technical corrections released in July 2022, the U.S. Treasury Department and IRS released proposed FTC regulations on November 18. The proposed regulations address the following issues:
- Definition of a reattribution asset for purposes of allocating and apportioning foreign income taxes
- Application of the cost recovery requirement
- Application of the source-based attribution requirement to withholding taxes on certain royalty payments.
Please join KPMG professionals from the International Tax group of the firm’s Washington National Tax practice for an overview of the proposed regulations, examples of how they would work if finalized, and what affected taxpayers should be considering now in response to the proposed rules.