N-2023-55: Temporary Relief Under Sections 901 and 903 of the Internal Revenue Code

Notice 2023-55 announces temporary relief for taxpayers in determining whether a foreign tax is eligible for a foreign tax credit under sections 901 and 903. For foreign taxes paid during tax years 2022 and 2023, taxpayers may apply: (1) former § 1.901-2(a) and (b), before it was amended by Treasury Decision 9959 (the 2022 FTC final regulations), but subject to a modification to the nonconfiscatory gross basis tax rule as described in the notice, and (2) existing § 1.903-1 without the attribution requirement. The notice also announces that the Treasury Department and the IRS are considering amendments to the 2022 FTC final regulations and whether, and under what conditions, to extend the relief described in the notice to tax years following the 2023 tax year.

Notice 2023-55 will be in IRB-2023-32, dated 08/07/2023.

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