Final regulations issued on treatment of overall foreign and domestic losses (OFLs and ODLs) for FTC limitation

The US Treasury Department and the Internal Revenue Service (IRS) have issued final regulations (TD 9595) with guidance on recapture of overall domestic losses (ODLs) and other issues related to the computation of the US foreign tax credit (FTC) limitation under section 904 of the US Internal Revenue Code (IRC).

The United States allows a foreign tax credit (FTC) for foreign taxes on foreign-source income, but IRC section 904 generally imposes a limitation on the FTC to prevent foreig…