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Tax Law Roundup current law developments in U.S. taxation

Tag Archives: CFTE

Temporary Regulations Address Allocation of Creditable Foreign Tax Expense

Posted in International, Partnership/LLC, Tax Credits

The IRS published temporary and proposed regulations on allocations of creditable foreign tax expenditures (CFTEs).  The regulations make various technical changes to the existing regulatory safe harbor for allocating CFTEs.  The regulations are effective on February 4, 2016. The existing regulations provide special rules for foreign tax expense allocations when those expenses are eligible for… Continue Reading