sourcing rules

TEI Files Comments regarding Proposed Regulations addressing the Foreign Tax Credit

On February 18, TEI submitted comments to the IRS and U.S. Treasury Department regarding proposed regulations related to the U.S. foreign tax credit. TEI’s comments primarily addressed the administrative burden the proposed regulations would impose on claiming a foreign tax credit due to a foreign tax redetermination under section 905(c), as well as issues related to “stewardship” expenses.
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