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Treasury and the IRS on 11 December released Notice 2023-80, announcing their intention to issue proposed regulations to address application of the foreign tax credit (FTC) and related rules and the dual consolidated loss (DCL) rules to certain types of taxes described in the GloBE Model Rules. The Notice also extends and modifies the temporary relief described in Notice 2023-55 for determining whether a foreign tax is eligible for an FTC under Sections 901 and 903. The Notice addresses application of the temporary relief with respect to partnerships and their partners. 

Comments on the guidance provided on the GloBE Model Rules and the FTC and the GloBE Model Rules and DCLs should be submitted by 9 February 2024.