Prop. Treas. Reg. § 1.965-5 Allowance of credit or deduction for foreign income taxes.

Proposed 2024-12-02 · REG-105479-18 · 89 FR 95362 · Interprets § 965 · Would amend § 1.965-5

Par. 31. Section 1.965-5 is amended by: 1. In the introductory text of paragraph (d)(1), removing the language “and (d)(3)” and adding the language “through (d)(5)” in its place; and 2. Adding paragraph (d)(5). The addition reads as follows:

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(d) * * *

(5) Adjusted applicable percentage for certain taxable years. For taxable years to which §§ 1.959-1 through 1.959-7 and 1.959-10 and 1.959-11 apply ( see § 1.959-12), the term applicable percentage means “adjusted applicable percentage” as defined in § 1.959-2(b)(2)(iii)(A), except for purposes of § 1.959-11(c)(3) (initial determination of the adjusted applicable percentage).