On September 29, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final foreign tax credit regulations (the “2020 Final Regulations”) that include the allocation and...more
10/21/2020
/ Allocation of Funds ,
Apportionment ,
CFC ,
Foreign Tax Credits ,
GILTI tax ,
IRS ,
New Regulations ,
Popular ,
Proposed Regulation ,
Research and Development ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On July 20, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final section 951A regulations (“Final Regulations”) on an election to exclude high-tax global intangible low-taxed...more