Prop. Treas. Reg. § 1.245A(d)-1 Disallowance of foreign tax credit or deduction.

Proposed 2024-12-02 · REG-105479-18 · 89 FR 95362 · Interprets § 245A(d) · Would amend § 1.245A(d)-1

Par. 3. Section 1.245A(d)-1 is amended by: 1. Revising the first sentence of paragraph (c)(22); and 2. For each paragraph listed in the table, removing the language in the “Remove” column wherever it appears and adding in its place the language in the “Add” column: The revision reads as follows:

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(c) * * *

(22) * * * The term section 245A(d) PTEP means previously taxed earnings and profits assigned to a section 245A(d) PTEP group or a reclassified section 245A(d) PTEP group (each as defined in § 1.959-1(b)). * * *

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