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

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. § 965.

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).