INCOME TAX

REG-101657-20, page 1466. This document contains proposed regulations relating to the foreign tax credit, including guidance on the disallowance of a credit or deduction for foreign income taxes with respect to dividends eligible for a dividends-received deduction; the allocation and apportionment of interest expense, foreign income tax expense, and certain deductions of life insurance companies; the definition of a foreign income tax and a tax in lieu of an income tax; transition rules relating to the impact on loss accounts of net operating loss carrybacks allowed by reason of the Coronavirus Aid, Relief, and Economic Security Act; the definition of foreign branch category and financial services income; and the time at which foreign taxes accrue and can be claimed as a credit. This document also contains proposed regulations clarifying rules relating to foreign-derived intangible income

REV. PROC. 2020-48, page 1459. This revenue procedure prescribes discount factors for the 2020 accident year for insurance companies to compute discounted unpaid losses under § 846 of the Internal Revenue Code and discounted estimated salvage recoverable under § 832.

T.D. 9922, page 1139. This document contains final regulations that modify the foreign tax credit provisions following the Tax Cuts and Jobs Act. This document contains additional changes to the existing regulations regarding the allocation and apportionment of expenses. Additionally, this document contains guidance on the allocation and apportionment of foreign income taxes to categories of income for purposes of the foreign tax credit. This document also contains final regulations addressing hybrid deduction accounts, certain hybrid instruments, and certain payments under section 951A. Finally, this document

also contains numerous other conforming changes to the existing foreign tax credit rules.

NOTICE 2020-75, page 1453. This notice announces that the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) intend to issue proposed regulations to clarify that State and local income taxes imposed on and paid by a partnership or an S corporation on its income are allowed as a deduction by the partnership or S corporation in computing its non-separately stated taxable income or loss for the taxable year of payment.