Internal Revenue Service September 24, 2021 – Federal Register Recent Federal Regulation Documents

Guidance on the Treatment of Qualified Improvement Property Under Sections 250(b) and 951A(d) and Guidance Related to the Foreign Tax Credit
Document Number: 2021-20615
Type: Rule
Date: 2021-09-24
Agency: Internal Revenue Service, Department of Treasury, Department of the Treasury
This document contains final regulations under sections 250 and 951A addressing the calculation of qualified business asset investment (``QBAI'') for qualified improvement property (``QIP'') under the alternative depreciation system (``ADS''). This document also contains final regulations with transition rules relating to the impact on loss accounts of net operating loss (NOL) carrybacks allowed by reason of the Coronavirus Aid, Relief, and Economic Security Act (the ``CARES Act''). The final regulations affect United States shareholders of controlled foreign corporations, domestic corporations eligible for the section 250 deduction, and taxpayers that claim credits or deductions for foreign income taxes.
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