Date: 2019-12-17
Links to Federal Register: HTML, PDF
(Proposed Regulation: REG-105600-18 HTML, PDF)
Document Number: 2019-24848, RIN: 1545-AC09
Action: Final and temporary regulations, and removal of temporary regulations.
Abstract: This document contains final regulations that provide guidance relating to the determination of the foreign tax credit under the Internal Revenue Code. The guidance relates to changes made to the applicable law by the Tax Cuts and Jobs Act, which was enacted on December 22, 2017. This document finalizes the proposed regulations published on December 7, 2018. This document also finalizes proposed regulations on overall foreign losses that were published on June 25, 2012, and finalizes certain portions of proposed regulations published on November 7, 2007, relating to a U.S. taxpayer's obligation to notify the IRS of a foreign tax redetermination.
| Notable phrases | Frequency |
|---|---|
| controlled foreign corporation | 343 |
| foreign income taxes | 258 |
| foreign branch category | 189 |
| passive category (gross) income | 180 |
| general category (gross) income | 175 |
| income group(s) | 173 |
| disregarded payment(s) | 140 |
| section 951A category | 132 |
| foreign branch category (gross) income | 123 |
| foreign branch owner | 111 |
| United States shareholder | 107 |
| statutory grouping | 101 |
| allocated and apportioned | 89 |
| previously taxed earnings and profits | 86 |
| section 245A subgroup | 79 |
| books and records | 77 |
| 10-percent owned foreign corporation | 71 |
| subpart F income group | 63 |
| section 904 category | 62 |
| gross tested income | 57 |
| foreign tax redetermination | 55 |
| annual PTEP account | 46 |
| burden | 45 |
| PTEP group taxes | 43 |
| foreign personal holding company income | 38 |
| tax book value | 36 |
| separate limitation loss | 29 |
| attributable to the foreign branch | 28 |
| section 250 deduction | 28 |
| foreign income taxes deemed paid | 23 |
| subpart F income statutory grouping | 21 |
| wholly-owned subsidiary | 21 |
| Reg. Cites | Frequency |
|---|---|
| 1.861-8 | 33 |
| 1.960-3 | 26 |
| 1.904-4 | 25 |
| 1.960-1(d)(3)(ii) | 22 |
| 1.904-6 | 19 |
| 1.861-14T | 17 |
| 1.904-5(a)(4)(v) | 17 |
| 1.960-2 | 17 |
| 1.861-17 | 15 |
| 1.861-13 | 14 |
| 1.861-12 | 13 |
| 1.904(b)-3 | 12 |
| 1.905-3 | 12 |
| 1.904-5 | 10 |
| 1.986(a)-1(a)(2)(iv) | 10 |
| 1.960-1 | 10 |
| 1.861-9 | 10 |
| 1.904-4(f) | 9 |
| 1.904(g)-3 | 8 |
| 1.861-12(c)(2) | 8 |
| Sec. Cites | Frequency |
|---|---|
| 951A | 184 |
| 904 | 143 |
| 245A | 105 |
| 901 | 47 |
| 951(a)(1)(A) | 43 |
| 960 | 42 |
| 959(b) | 39 |
| 960(a) | 38 |
| 250 | 37 |
| 951(a) | 37 |
| 951(a)(1) | 35 |
| 78 | 35 |
| 951A(a) | 31 |
| 960(b) | 29 |
| 959(c)(2) | 28 |
| 902 | 27 |
| 959(a) | 23 |
| 987 | 21 |
| 904(a) | 20 |
Statistics
Number of pages: 102, words: 119,751, sentences: 4,096
Average words per sentence: 29