Foreign Tax Credit Allocation and Disallowance (IRC §§ 898©, 960(d)(4))
Current understanding
To be populated as evidence accumulates.
Evidence log
- 2026-08-03 — Section 898© Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance: Proposed Treasury/IRS regulations establish a transition rule under IRC §898© for allocating foreign taxes of foreign corporations following repeal of the one-month deferral election, and implement §960(d)(4) to disallow foreign tax credits on certain distributions of previously taxed earnings and profits. (novelty: 2)
Open questions
Related
Contributing findings
Section 898(c) Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance
03-aug-2026
novelty 2
per-area 2
introduces