2022 Final Foreign Tax Credit Regulations


On January 4, 2022, the Treasury and the IRS published T.D. 9959, finalizing portions of the third set of proposed foreign tax credit regulations published in the Federal Register in November 2020.

This complimentary OnPoint – an exclusive summary of ready-to-use presentation slides – highlights what you need to know.

Key terms and rule changes include:

  • Definition of Creditable Foreign Income Tax­
  • Net Gain Requirement­
  • Definition of In-Lieu-Of Tax­
  • Timing Rules for Claiming a FTC­
  • Allocation and Apportionment of Foreign Income Taxes­
  • Disallowance of FTC or Deductions Under 245A(d)­
  • Other Foreign Tax Credit Rules­
  • Clarifications of Foreign-Derived Intangible Income­
  • Rules Not Finalized or Previously Finalize

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