Proposed regs would add new types of covered asset acquisitions for foreign tax credit limitation purposes. The IRS has proposed regulations that would provide rules for computing the disqualified portion of foreign income taxes under the tax code that isn’t taken into account for purposes of calculating the foreign income tax credit. The “901(m) regs” would cover transactions that generally are treated as asset acquisitions for U.S. income tax purposes, but that are either treated as stock acquisitions or disregarded for foreign income tax purposes.
