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.
See https://public-inspection.federalregister.gov/2022-25337.pdf
Posted by Benjamin Sapozhnikov, Associate Editor, Wealth Strategies Journal.
Wealth Strategies Journal 