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

Proposed regulation, not in force. REG-105479-18, 89 FR 95362, published 2024-12-02 <https://www.federalregister.gov/documents/2024/12/02/2024-27227/previously-taxed-earnings-and-profits-and-related-basis-adjustments>. Interprets 26 U.S.C. § 245A.

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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