Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance; Correction
This document contains corrections to the proposed regulations (REG-115145-25), published in the Federal Register on August 3, 2026. These proposed regulations relate to allocating foreign taxes of foreign corporations affected by the repeal of the one-month deferral election…
This document contains corrections to the proposed regulations (REG-115145-25), published in the Federal Register on August 3, 2026. These proposed regulations relate to allocating foreign taxes of foreign corporations affected by the repeal of the one-month deferral election…
BELLINGS Intelligence Score: 38
Why it matters
This correction to proposed IRS regulations on foreign tax credit allocation affects multinational tax compliance and could influence cross-border tax planning and credit availability, relevant to sophisticated credit professionals dealing with international borrowers and investments.
Sources
Federal Register
Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance; Correction
This document contains corrections to the proposed regulations (REG-115145-25), published in the Federal Register on August 3, 2026. These proposed regulations relate to allocating foreign taxes of foreign corporations affected by the repeal of the one-month deferral election…