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Taxes phase ten rules12/7/2023 ![]() ![]() ![]() Lastly, the Final Regulations narrow the scope of services that constitute electronically supplied services for purposes of the rules under IRC Section 250 on foreign-derived intangible income (FDII). The Final Regulations also provide guidance on allocating and apportioning foreign taxes paid or accrued with respect to certain transactions that are disregarded for US federal tax purposes, the disallowance of a credit or deduction for certain foreign income taxes, when foreign income taxes accrue, and various issues relevant for determining a taxpayer's foreign tax credit limitation. The Final Regulations fundamentally revamp the rules for determining the creditability of a foreign tax under IRC Sections 901 and 903, including by requiring a foreign tax to meet an attribution requirement (known as the "jurisdictional nexus requirement" in the Proposed Regulations). For an Alert discussing the Proposed Regulations, see Tax Alert 2020-2645. The Final Regulations adopt proposed regulations that were published on 12 November 2020 (the Proposed Regulations), with some modifications. 9959, the Final Regulations) on foreign tax credits since the enactment of the Tax Cuts and Jobs Act (TCJA). On 4 January 2022, the United States (US) Treasury Department published its third set of final regulations ( T.D. ![]() Foreign tax credit regulations revamp creditability rules for foreign income taxes and include several other key changes ![]()
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