Silicon Valley Group Finds Room for Improvement in FTC Regs

Silicon Valley Group Finds Room for Improvement in FTC Regs

Silicon Valley Tax Directors Group

The Silicon Valley Tax Directors Group has recommended many changes to proposed foreign tax credit regulations (<a href="/lr/resolve//2b5rz">REG-105495-19</a>), including the modification of provisions dealing with allocation and apportionment of research and experimental expenses and a suggestion that stewardship expenses should be allocated and apportioned based on income.

The Silicon Valley Tax Directors Group has recommended many changes to proposed foreign tax credit regulations (REG-105495-19), including the modification of provisions dealing with allocation and apportionment of research and experimental expenses and a suggestion that stewardship expenses should be allocated and apportioned based on income.

The Silicon Valley Tax Directors Group has recommended many changes to proposed foreign tax credit regulations (REG-105495-19), including the modification of provisions dealing with allocation and apportionment of research and experimental expenses and a suggestion that stewardship expenses should be allocated and apportioned based on income.

Sec. 861 Income from sources within the United States

Sec. 904 Limitation on credit

Sec. 954 Foreign base company income

Sec. 965 Treatment of deferred foreign income upon transition to participation exemption system of taxation

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Silicon Valley Group Finds Room for Improvement in FTC Regs