188bet亚洲真人体育下载 comments to IRS on proposed foreign tax credit regulations

的 American Institute of CPAs (188bet亚洲真人体育下载) has made recommendations to the Internal Revenue Service (IRS) about its proposed regulations Guidance Related to the Foreign 税 Credit, Including Guidance Implementing Changes Made by the 税 Cuts and Jobs Act (TCJA) (reg - 105600 - 18).

的焦点 188bet亚洲真人体育下载 recommendations is to clarify in which foreign tax credit basket various categories of income and expenses should be properly assigned as a result of changes made by the TCJA.

的 188bet亚洲真人体育下载 made recommendations about the proposed regulations in the following six areas:

• Determination of stock basis in connection with Internal Revenue Code section 965(b);
• Allocation and apportionment of re搜索 and experimentation expenses;
• Characterizing the stock of a noncontrolled 10-percent corporation;
• Attributing current year taxes to a Controlled Foreign Corporation’s earnings and profits described in section 959(c)(3);
• Modify the definition of an “exempt asset” as it relates to assets that generate foreign-derived intangible income; and
• Clarify when a withholding tax imposed on a disregarded dividend is related to a Subpart F or Tested Income Group.