Our International Tax Group delves into the attribution requirement (née jurisdictional nexus requirement) of the final foreign tax credit regulations and finds that taxpayers will still face uncertainties in the application of the foreign tax credit.
- The IRS seeks to modernize regulations to mitigate double taxation of foreign-source income
- Many of the final regulations follow the proposed regulations, but some were modified based on comments from taxpayers
- Gray areas remain, including how reasonably similar a foreign rule must be
Read the full advisory here.
