Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit

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In the Rules and Regulations section in this issue of the Federal Register, the IRS is issuing temporary regulations that provide guidance relating to the determination of the amount of taxes paid for purposes of the foreign tax credit. These regulations address certain highly structured arrangements that produce inappropriate foreign tax credit results. The text of those temporary regulations published in this issue of the Federal Register also serves as the text of these proposed regulations.