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April 3, 2023

IRS plans to extend foreign tax credit transition period for documenting 'single-country exception'

The IRS has announced (Notice 2023-31) that it intends to provide a longer transition period for meeting the documentation requirements (in Treas. Reg. Section 1.903-1(c)(2)(iv)(D)) for the foreign tax credit "single-country exception" (under Prop. Treas. Reg. Section 1.903-1(c)(2)(iii)(B)) by providing a 180-day period after the regulations are finalized.

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor