Proposed Regulations Provide New Rules for Allocating and Apportioning Foreign Income Taxes Relating to Disregarded Payments
By EsqSocial Corporation 24/12/20
On November 12, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) published proposed regulations (REG-101657-20) (the “2020 Proposed Regulations”) in the Federal Register that contain a new comprehensive set of rules addressing the allocation and apportionment of foreign income taxes relating to foreign gross income generated under foreign law by disregarded payments. Also on the same day, Treasury and the IRS published final regulations (TD 9922) (the...
By: McDermott Will & Emery