IMPACTS OF THE FINAL FOREIGN TAX CREDIT REGULATIONS: CREDIT DISALLOWANCE AND TIMING RULES
The 2021 final foreign tax credit (FTC) regulations make significant changes to the FTC rules for U.S. multinationals. In addition to a variety of other modifications, the final regulations overhaul the 2020 proposed regulations regarding the Section 245A dividends received deduction (DRD) to deny a credit or deduction for certain foreign income taxes paid or […]