REG-112096-22: IRS Announces Proposed Foreign Tax Credit Regulations(November 18, 2022)

The U.S. Department of the Treasury and the IRS have released proposed new regulations relating to the foreign tax credit. The proposed regulations include guidance on the reattribution asset rule for purposes of allocating and apportioning foreign taxes, the application of the cost recovery requirement, and the application of attribution rule for withholding tax on royalty payments.


Posted by Benjamin Sapozhnikov, Associate Editor, Wealth Strategies Journal.

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s