N-2022-42, foreign tax credit

Notice 2022-42 addresses the application of the noncompulsory payment rules in the foreign tax credit regulations to amended tax decrees between MNEs and the Puerto Rico tax authority.? The Notice assures taxpayers and their affiliates that the amendment of an existing decree prior to 12/31/2022 that results in the imposition of Puerto Rico taxes at rates lower than those that would apply in the absence of a decree will not be viewed as resulting in noncompulsory payments even if the taxpayer and its affiliates may have paid less with respect to one or more levies under their prior tax decree.? The relief is intended to provide certainty and aid Puerto Rico?s transition away from the excise tax and modified ECI tax, which will no longer be creditable beginning next year.?

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