The IRS released for publication in the Federal Register final regulations (T.D. 9871) concerning the allocation by a partnership of foreign income taxes to partners. Specifically, the regulations concern the rules for allocations of “creditable foreign tax expenditures.”
The final regs adopt and finalize regulations that were proposed in 2016 with certain minor clarifications.
Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal..