Treasury Grants Foreign Tax Credit, GILTI Relief On R&D Costs

Law360 (December 2, 2019, 4:51 PM EST) -- The U.S. Department of the Treasury issued rules Monday that offer some relief to companies that owe large payments on global intangible low-taxed income by excluding research and development costs as expenses that can increase foreign tax credit limitations.

Treasury issued rules confirming that research and development expenses do not have to be allocated against foreign income. (AP) Treasury also finalized proposed regulations, issued last year, that allow companies to claim some increased foreign tax credits against their GILTI liability. But the final rules don't include the broader exclusions advocated by companies that said the interaction between the foreign tax credit limitations and...

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