N-2023-80: Guidance Regarding the Foreign Tax Credit and Dual Consolidated Losses in Relation to the GloBE Model Rules, and Extension and Modification of Temporary Relief in Notice 2023-55

Notice 2023-80 announces that Treasury and the IRS intend to issue proposed regulations to address the application of the foreign tax credit and related rules and the dual consolidated loss (DCL) rules to certain types of taxes described in the GloBE Model Rules. This notice also extends and modifies the temporary relief described in Notice 2023-55 for determining whether a foreign tax is eligible for a foreign tax credit under §§ 901 and 903.

Notice 2023-80 will be in IRB: 2023-52, dated 12/26/2023.

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