US Treasury and the IRS released final regulations under Sections 245A, 301, 704, 861, 881, 904, 905, 954, 960, 965, 1502; and proposed regulations under Sections 164, 245A, 250, 336, 338, 367, 861, 901, 903, 904, 905, and 960. The final and proposed regulations provide administrative guidance for the Foreign Tax Credit (FTC) regime, which was updated in the 2017 tax reform act.
PwC will publish a detailed analysis of the final and proposed regulations within the coming days.
