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Section on Taxation: New Guidance – Temporary Relief from Recent Regulations on Foreign Tax Creditability
This panel will discuss IRS Notice 2023-55 and its impact on U.S. multinational entities. IRS Notice 2023-55 provides temporary relief for taxpayers determining whether a foreign tax is eligible for a foreign tax credit under sections 901 and 903. Section 901 allows a credit for foreign income, war profits, and excess profits taxes; section 903 allows a credit for taxes paid in lieu of a generally imposed foreign income, war profits, or excess profits tax. 2022 regulations revised the rules for determining whether a foreign levy is a creditable foreign income tax under sections 901 and 903. The temporary relief offered through IRS Notice 2023-55 allows taxpayers to apply certain portions to of the prior regulations under section 901 rather than the 2022 regulations, and also turns off portions of the new regulations under section 903. This panel will discuss the implications of the notice and what companies can expect in the future.
Presented by the Section on Taxation
Presenters
- Teisha Ruggiero, Senior Counsel, IRS Office of Chief Counsel
- Deborah Tarwasokono, Attorney-Advisor, Department of Treasury
- Brian Jenn, Partner, McDermott Will & Emery
- Ray Stahl, Principal, EY
- Marissa Rensen, Managing Director, KPMG
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CLE
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