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November 18, 2022

Thursday, December 1 | New proposed foreign tax credit regulations: What changed, what didnít, and what could it all mean for your company? (2 pm ET)

Join us for an update on the newly released proposed foreign tax credit regulations. The proposed regulations make several changes to address issues identified in the December 2021 final foreign tax credit regulations. Those final foreign tax credit regulations significantly changed the rules on determining what is a creditable foreign income tax; some of these changes had the potential to render many long-standing creditable taxes noncreditable.

The new proposed regulations revise the cost recovery requirement and the rules for royalty withholding taxes. The proposed regulations also include changes to the rules for allocating and apportioning foreign taxes with respect to disregarded transactions of property.

Our panel of international tax professionals from Ernst & Young LLP’s National Tax Department will discuss how these changes may affect companies’ ability to claim foreign tax credits, as well as other business implications.

Date: Thursday, December 1, 2022

Time: 2:00–3:00 p.m. ET New York; 11:00 a.m.–12:00 p.m. PT Los Angeles

Registration: View archive here.


  • JD Hamilton, Partner, International Tax and Transaction Services, Ernst & Young LLP
  • Ray Stahl, Principal, International Tax and Transaction Services, Ernst & Young LLP
  • Jason Yen, Principal, International Tax and Transaction Services, Ernst & Young LLP


  • Colleen O’Neill, Partner, Director of International Tax and Transaction Services, National Tax Department, Ernst & Young LLP

CPE credit offered: up to 1.2 depending on duration. Recommended field of study: Taxes. Learning objectives: Identify changes to requirements in the new proposed foreign tax credit regulations; recognize the potential implications of the proposed regulations for businesses claiming the credit. This intermediate level, group internet-based course has no prerequisites or advanced preparation. Final CPE award to be based on content, polling and length of participation. See CPE FAQ for more information.

EY webcast managed and produced by the Ernst & Young LLP Tax Technical Knowledge Services Group, Washington, DC: Lynn Fairfax | and Barbara Kirchheimer |

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