Collected Comments on Proposed Regs: Foreign Tax Credit

The IRS has scheduled a May 20 public hearing on proposed regulations (REG-105495-19) that provide guidance on the allocation and apportionment of deductions and creditable foreign taxes, the definition of financial services income, foreign tax redeterminations, availability of foreign tax credits under the transition tax, and the application of the FTC limitation to consolidated groups.

Documents

The following documents are available from Tax Analysts:

• Comments from Sen. David Perdue, R-Ga.

• Comments from Securities Industry and Financial Markets Association on January 16, 2020, and February 18, 2020.

• Comments from New York State Bar Association Tax Section.

• Comments from AFLAC.

• Comments from U.S. Chamber of Commerce.

• Comments from Deloitte Tax LLP.

• Comments from Tax Executives Institute.

• Comments from Alliance for Competitive Taxation.

• Comments from National Foreign Trade Council.

• Comments from United States Council for International Business.

• Comments from American Council of Life Insurers.

• Comments from Semiconductor Industry Association.

• Comments from EY.

• Comments from American Property Casualty Insurance Association, National Association of Mutual Insurance Companies, and Reinsurance Association of America.

• Comments from Investment Company Institute.

• Comments from Fenwick & West LLP on February 18, 2020, and February 19, 2020.

• Comments from American Petroleum Institute.

• Comments from McDermott Will & Emery LLP.

• Comments from Covington & Burling LLP.

• Comments from Silicon Valley Tax Directors Group.

• Comments from Information Technology Industry Council.

• Comments from National Association of Manufacturers.

• Comments from Miller & Chevalier.

• Comments from several individuals.

• Comments from American Institute of CPAs.