United States: Controversial FTC regulations temporarily suspended ─ Not a moment too soon!

Tax news and developments

In brief

Notice 2023-55 suspends, for the 2022 and 2023 taxable years, the application of significant portions of controversial final foreign tax credit regulations. The Notice suspends, for foreign levies that are not digital services taxes, the heavily debated rules in the 2022 FTC final regulations for determining whether a foreign levy is an “income tax” for US tax purposes, including the net gain, cost recovery and attribution requirements.


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