Section 861

TEI Comments on Proposed Foreign Tax Credit Regulations

On February 5, 2019, TEI submitted responsive comments and recommendations to the Internal Revenue Service concerning the new proposed regulations under sections 861 and 904 of the Code (REG-105600-18). TEI’s comments, which are reprinted below, were developed by a cross-industry working group of Tax Reform Task Force and U.S. International Tax Committee members under the stewardship of TEI lawyers Watson M. McLeish and Benjamin R. Shreck.