Government Releases Final Foreign Tax Credit Regulations on Stewardship and R&E Expenses

On September 29, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final foreign tax credit regulations (the “2020 Final Regulations”) that include the allocation and apportionment of: (1) stewardship expenses; and (2) research and experimentation (R&E) expenses. The 2020 Final Regulations come after the Treasury and IRS issued proposed regulations (the “2019 Proposed Regulations”) on December 17, 2019. The 2020 Final Regulations retain...
By: McDermott Will & Emery

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