Foreign Tax Credit Final Regulations and 2019 Proposed Regulations

Foreign Tax Credit Final Regulations and 2019 Proposed Regulations

December 5, 2019, Covington Alert

On December 2, 2019, the U.S. Department of the Treasury ("Treasury Department") and the Internal Revenue Service ("IRS") released final regulations, as well as new proposed regulations (the “2019 proposed regulations”), addressing issues related to the determination of foreign tax credits in light of the changes made by the Tax Cuts and Jobs Act (“TCJA”).