03 April 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. Document ID: 2023-0643 |