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AICPA Comments to IRS on Proposed Foreign Tax Credit Regulations



The AICPA recently made recommendations to the IRS about its proposed regulations Guidance Related to the Foreign Tax Credit, Including Guidance Implementing Changes Made by the Tax Cuts and Jobs Act (TCJA) (REG-105600-18).


Recommendations were made in the following areas:


  1. Stock basis determination in connection with IRS Code section 965(b)

  2. Allocation/apportionment of research and experimentation expenses

  3. Stock characterization of a noncontrolled 10-percent corporation

  4. Attributing current year taxes to a Controlled Foreign Corporation’s earnings and profits

  5. Modification of the definition of an “exempt asset” as it relates to assets generating foreign-derived intangible income

  6. Clarification when a withholding tax imposed on a disregarded dividend is related to Subpart F or Tested Income Group

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