2022 Proposed Foreign Tax Credit Regulations

On November 18, 2022, the Treasury Department published Foreign Tax Credit guidance aimed to clarify royalty withholding tax and cost recovery areas.

The measures would give companies a way to make sure their foreign royalty withholding taxes can continue to qualify for the credit. The rule also would make clear that a country’s restrictions on whether taxpayers can recover their costs don’t necessarily prevent their taxes there from being eligible for the credit.

This complimentary OnPoint – a summary of ready-to-use presentation slides —explains the key proposals and what you need to know.

Topics include:

  • Clarifications to the cost recovery requirement
  • New cost recovery safe harbor
  • Source-based attribution rule for royalties
  • Foreign tax credit for foreign royalty withholding taxes

Download your copy to understand the impacts to your business.

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