IRS has issued final regulations relating to the recapture of overall domestic losses under Code Sec. 904(g), enacted as part of the American Jobs Creation Act of 2004 ( P.L. 108-357). The regulations also provide updated guidance with respect to overall foreign losses and separate limitation losses and can impact the amount of a taxpayers’ foreign source income. They affect individuals and corporations claiming foreign tax credits. The final rule is effective as of June 22, 2012, and is available in the Federal Register at Treatment of Overall Foreign and Domestic Losses (TD 9595).
IRS final regulations on treatment of overall foreign and domestic losses
July 9th, 2012 by TaxOps