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September 21, 2021

IRS final regulations address treatment of qualified improvement property and provides guidance on foreign tax credits

Final regulations (TD 9956) under IRC Sections 250 and 951A address how to calculate qualified business asset investments for qualified improvement property under the alternative depreciation system. Transition rules in TD 9956 address the impact that NOL carrybacks allowed under the CARES Act have on loss accounts. Taxpayers affected by the final regulations include: US shareholders of controlled foreign corporations; domestic corporations eligible for deductions for foreign-derived intangible income and global intangible low-taxed income; and taxpayers claiming credits or deductions for foreign income taxes. (For background, see Tax Alert 2020-2864.)