The New FTC Regs: Calculating tax in a galaxy far, far away

Doug McHoney (PwC's US International Tax Services Leader) and Tim Anson (International Tax Partner in PwC's Washington National Tax Services practice) discuss the recently issued final and proposed foreign tax credit (FTC) regulations. Doug and Tim discuss: the FTC's interplay with global intangible low-taxed income (GILTI); how 'branch IP' is treated in the final FTC regulations; how the final regulations treat expense allocation and apportionment at the CFC level; how the final regulations treat 'deemed paid' credits, including in foreign jurisdictions with different tax year-ends; how the final regulations interplay with Section 905(c) to create the potential for a multitude of amended returns; how the proposed FTC regulations treat research and experimentation apportionment; how the proposed regulations treat stewardship expenses; and how the proposed regulations provide specific rules for timing or base differences under Prop. Reg. sec. 1.861-20 (also known as 'dash 20.').