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Partner Amanda Varma authored an article titled, “Foreign
Tax Credit Considerations After Notice 2023-55” for
Bloomberg Tax Management International Journal.
Notice 2023-55 provides taxpayers with temporary relief from
applying certain provisions of the final regulations that
overhauled longstanding rules for determining whether a foreign tax
is creditable (the “2022 Final Regulations”). The notice
is the latest, and most significant, acknowledgment by Treasury and
the IRS that the final regulations raise major issues. For the many
taxpayers grappling with the new rules, the relief in the notice is
very welcome. The relief is not, however, a panacea—it is
temporary and leaves certain major issues unresolved. Treasury and
the IRS have said they are considering extending the relief, though
it remains to be seen whether the government will expand either the
applicability date of the notice, the scope, or both. At the same
time, the government and taxpayers are confronting new foreign tax
credit questions due to global and US developments, including
questions about the credibility of foreign taxes likely to be
enacted consistent with the OECD’s Pillar 2 aspects as well as
questions about the foreign tax credit provisions of the corporate
alternative minimum tax.
Read the article at Bloomberg
Tax Management International Journal
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