Andrew Mitchel LLC

International Tax Blog - New and Interesting International Tax Issues


Chart of Example in Notice 2025-77

2025-12-20

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The IRS recently published Notice 2025-77. This notice discusses the new rule in Code §960(d)(4) where 10% of foreign income taxes paid or accrued with respect to 951A PTEP distributions are disallowed. Section 3.02 of Notice 2025-77 includes an example. We created a chart of the example.

Tags: 901 Foreign Tax Credits, 951A GILTI, 960 Deemed Paid Foreign Taxes