Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income

Why it matters

The proposed regulations on allocation and apportionment of deductions to foreign source income affect tax treatment and compliance for multinational entities, which is relevant to credit-market professionals managing cross-border exposures, but as a proposal without immediate market impact, it is notable but not highly significant.

Sources

• Federal Register

  Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income

  This document contains proposed regulations related to the allocation and apportionment of deductions to foreign source section 951A category income for foreign tax credit limitation purposes and for purposes of calculating deduction eligible income. The proposed regulations…