On March 31, 2024, TEI submitted comments to the Internal Revenue Service (the "Service") regarding foreign tax redeterminations ("FTRs") under section 905(c). The post-TCJA final regulations resulted in a significant increase in the compliance burden on taxpayers with FTRs. TEI's letter recommended several methods to reduce this compliance burden as well as the administrative burden on the Service when auditing FTRs. TEI's comments were prepared under the aegis of its U.S. International Tax Committee, whose Chair is Ag Samoc. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI's comments.
Committee