KPMG has made available for download their article, “Foreign tax credit and certain deductions of life insurance companies (final regulations),” which raises concerns regarding the foreign tax credit and clarify rules on foreign-derived intangible income (FDII) . The abstract is as follows:
Over the past several years, Treasury and the IRS have issued a series of proposed and final regulations detailing the foreign tax credit and related rules.
More recently, proposed regulations (REG 101657-20) released in November 2020 (“2020 FTC proposed regulations”) included guidance relating to the allocation and apportionment of creditable foreign taxes and deductions (including certain deductions for life insurance companies).
T.D. 9959 finalizes certain provisions of the 2020 FTC proposed regulations, including certain deductions of life insurance companies. The following discussion focuses on these insurance provisions.
To see the full article, click: “Foreign tax credit and certain deductions of life insurance companies (final regulations)“.
Posted by Jessica Ji, Associate Editor, Wealth Strategies Journal.