{"abstract":"This document contains proposed regulations relating to the foreign tax credit, including guidance on the disallowance of a credit or deduction for foreign income taxes with respect to dividends eligible for a dividends-received deduction; the allocation and apportionment of interest expense, foreign income tax expense, and certain deductions of life insurance companies; the definition of a foreign income tax and a tax in lieu of an income tax; transition rules relating to the impact on loss accounts of net operating loss carrybacks allowed by reason of the Coronavirus Aid, Relief, and Economic Security Act; the definition of foreign branch category and financial services income; and the time at which foreign taxes accrue and can be claimed as a credit. This document also contains proposed regulations clarifying rules relating to foreign-derived intangible income. The proposed regulations affect taxpayers that claim credits or deductions for foreign income taxes, or that claim a deduction for foreign-derived intangible income.","action":"Notice of proposed rulemaking.","agencies":[{"raw_name":"DEPARTMENT OF THE TREASURY","name":"Treasury Department","id":497,"url":"https://www.federalregister.gov/agencies/treasury-department","json_url":"https://www.federalregister.gov/api/v1/agencies/497","parent_id":null,"slug":"treasury-department"},{"raw_name":"Internal Revenue Service","name":"Internal Revenue Service","id":254,"url":"https://www.federalregister.gov/agencies/internal-revenue-service","json_url":"https://www.federalregister.gov/api/v1/agencies/254","parent_id":497,"slug":"internal-revenue-service"}],"body_html_url":"https://www.federalregister.gov/documents/full_text/html/2020/11/12/2020-21818.html","cfr_references":[{"chapter":null,"citation_url":null,"part":"1","title":26}],"citation":"85 FR 72078","comment_url":null,"comments_close_on":"2021-02-10","correction_of":null,"corrections":[],"dates":"Written or electronic comments and requests for a public hearing must be received by February 10, 2021.","disposition_notes":null,"docket_ids":["REG-101657-20"],"dockets":[{"supporting_documents":[{"title":"Foreign Tax Credit: Clarification of Foreign-Derived Intangible Income; 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Clarification of Foreign-Derived Intangible Income (REG–101657–20)"}],"document_number":"2020-21818","effective_on":null,"end_page":72156,"executive_order_notes":null,"executive_order_number":null,"full_text_xml_url":"https://www.federalregister.gov/documents/full_text/xml/2020/11/12/2020-21818.xml","html_url":"https://www.federalregister.gov/documents/2020/11/12/2020-21818/guidance-related-to-the-foreign-tax-credit-clarification-of-foreign-derived-intangible-income","images":{},"images_metadata":{},"json_url":"https://www.federalregister.gov/api/v1/documents/2020-21818?publication_date=2020-11-12","mods_url":"https://www.govinfo.gov/metadata/granule/FR-2020-11-12/2020-21818/mods.xml","not_received_for_publication":null,"page_length":79,"page_views":{"count":8620,"last_updated":"2026-10-23 16:15:07 -0400"},"pdf_url":"https://www.govinfo.gov/content/pkg/FR-2020-11-12/pdf/2020-21818.pdf","presidential_document_number":null,"proclamation_number":null,"public_inspection_pdf_url":"https://public-inspection.federalregister.gov/2020-21818.pdf?1604333717","publication_date":"2020-11-12","raw_text_url":"https://www.federalregister.gov/documents/full_text/text/2020/11/12/2020-21818.txt","regulation_id_number_info":{"1545-BP70":{"issue":"202304","html_url":"https://www.federalregister.gov/regulations/1545-BP70/guidance-related-to-the-foreign-tax-credit-clarification-of-foreign-derived-intangible-income","title":"Guidance Related to the Foreign Tax Credit, Clarification of Foreign-Derived Intangible Income","xml_url":"http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202304&RIN=1545-BP70&operation=OPERATION_EXPORT_XML","priority_category":"Economically Significant"}},"regulation_id_numbers":["1545-BP70"],"regulations_dot_gov_info":{"supporting_documents":[{"title":"Foreign Tax Credit: Clarification of Foreign-Derived Intangible Income; Guidance; Correction","document_id":"IRS-2020-0040-0039"},{"title":"Foreign Tax Credit: Clarification of Foreign-Derived Intangible Income; Guidance; Correction","document_id":"IRS-2020-0040-0038"},{"title":"Guidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income","document_id":"IRS-2020-0040-0035"},{"title":"Foreign Tax Credit: Clarification of Foreign-Derived Intangible Income; Guidance","document_id":"IRS-2020-0040-0034"},{"title":"Public Hearing: Guidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income","document_id":"IRS-2020-0040-0031"},{"title":"Guidance: Allocation and Apportionment of Deductions and Foreign Taxes, Foreign Tax Redeterminations, Foreign Tax Credit Disallowance, Consolidated Groups, Hybrid Arrangements and Certain Payments","document_id":"IRS-2020-0040-0003"},{"title":"Guidance: Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income (REG–101657–20)","document_id":"IRS-2020-0040-0001"}],"regulatory_plan":{"html_url":"https://www.federalregister.gov/regulations/1545-BP70/guidance-related-to-the-foreign-tax-credit-clarification-of-foreign-derived-intangible-income","title":"Guidance Related to the Foreign Tax Credit, Clarification of Foreign-Derived Intangible Income"},"comments_count":35,"agency_id":"IRS","comments_url":"https://www.regulations.gov/docketBrowser?rpp=50&so=DESC&sb=postedDate&po=0&dct=PS&D=IRS-2020-0040","supporting_documents_count":7,"docket_id":"IRS-2020-0040","document_id":"IRS-2020-0040-0001","regulation_id_number":"1545-BP70","title":"Guidance: Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income (REG–101657–20)","checked_regulationsdotgov_at":"2023-03-01T03:40:44Z"},"regulations_dot_gov_url":null,"significant":true,"signing_date":null,"start_page":72078,"subtype":null,"title":"Guidance Related to the Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income","toc_doc":"Foreign Tax Credit; Clarification of Foreign-Derived Intangible Income","toc_subject":"Guidance:\n","topics":["Income taxes","Reporting and recordkeeping requirements"],"type":"Proposed Rule","volume":85}