Department of Treasury February 4, 2016 – Federal Register Recent Federal Regulation Documents

Allocation of Creditable Foreign Taxes
Document Number: 2016-01949
Type: Rule
Date: 2016-02-04
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains temporary regulations that provide guidance relating to the allocation by a partnership of creditable foreign tax expenditures. These temporary regulations are necessary to improve the operation of an existing safe harbor rule that is used for determining whether allocations of creditable foreign tax expenditures are deemed to be in accordance with the partners' interests in the partnership. The text of these temporary regulations also serves as the text of the proposed regulations set forth in the notice of proposed rulemaking (REG-100861-15) published in the Proposed Rules section in this issue of the Federal Register. These regulations affect partnerships that pay or accrue foreign income taxes, and their partners.
Allocation of Creditable Foreign Taxes
Document Number: 2016-01948
Type: Proposed Rule
Date: 2016-02-04
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
In the Rules and Regulations section in this issue of the Federal Register, the IRS is issuing temporary regulations that provide guidance relating to the allocation by a partnership of foreign income taxes. Those temporary regulations are necessary to improve the operation of an existing safe harbor rule that is used for determining whether allocations of creditable foreign tax expenditures are deemed to be in accordance with the partners' interests in the partnership. The text of those temporary regulations published in this issue of the Federal Register also serves as the text of these proposed regulations.