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TREAS/IRS | RIN: 1545-BP70 | Publication ID: Fall 2022 |
Title: Guidance Related to the Foreign Tax Credit, Clarification of Foreign-Derived Intangible Income | |
Abstract:
These regulations provide guidance related to the foreign tax credit, including guidance with respect to expense allocation, legal liability for foreign tax, transition rules relating to the impact on loss accounts of net operating loss carrybacks, definition of a foreign income tax, and when foreign taxes accrue and may be claimed as credit. The regulations also provide guidance clarifying rules relating to foreign-derived intangible income. |
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Agency: Department of the Treasury(TREAS) | Priority: Economically Significant |
RIN Status: Previously published in the Unified Agenda | Agenda Stage of Rulemaking: Final Rule Stage |
Major: Yes | Unfunded Mandates: No |
CFR Citation: 26 CFR 1.245A(d) 26 CFR 1.250(b) 26 CFR 367(b) 26 CFR 1.861 26 CFR 1.901 26 CFR 1.903 26 CFR 1.904 26 CFR 1.904(f) 26 CFR 1.905 26 CFR 1.960 ... (To search for a specific CFR, visit the Code of Federal Regulations.) | |
Legal Authority: 26 U.S.C. 7805 26 U.S.C. 245A(g) |
Legal Deadline:
None |
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Timetable:
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Additional Information: REG-111590-20; REG-101657-20 (Final) Drafter attorney: Tianlin (Laura) Shi (202) 317-6987 Reviewer attorney: Barbara Felker (202) 317-4925 Treasury attorney: Issac Wood (202) 622-1011 CC:INTL | |
Regulatory Flexibility Analysis Required: No | Government Levels Affected: None |
Federalism: No | |
Included in the Regulatory Plan: No | |
RIN Data Printed in the FR: No | |
Related RINs: Related to 1545-BP91 | |
Agency Contact: Tianlin Shi Attorney Department of the Treasury Internal Revenue Service 1111 Constitution Avenue NW., Washington, DC 20224 Phone:202 317-6987 Email: tianlin.shi@irscounsel.treas.gov |