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B-333023 Mar 01, 2021 1 (2021-03-01)

handle is hein.gao/gaolig0001 and id is 1 raw text is: O1O o U.S. GOVERNMENT ACCOUNTABILITY OFFICE A Century of Non-Partisan Fact-Based Work 441 G St. N.W. Washington, DC 20548 B-333023 March 1, 2021 The Honorable Ron Wyden Chairman The Honorable Mike Crapo Ranking Member Committee on Finance United States Senate The Honorable Richard Neal Chairman The Honorable Kevin Brady Ranking Member Committee on Ways and Means House of Representatives Subject: Department of the Treasury, Internal Revenue Service: Guidance Related to the Allocation and Apportionment of Deductions and Foreign Taxes, Foreign Tax Redeterminations, Foreign Tax Credit Disallowance Under Section 965(g), Consolidated Groups, Hybrid Arrangements and Certain Payments Under Section 951A Pursuant to section 801(a)(2)(A) of title 5, United States Code, this is our report on a major rule promulgated by the Department of the Treasury, Internal Revenue Service (IRS) entitled Guidance Related to the Allocation and Apportionment of Deductions and Foreign Taxes, Foreign Tax Redeterminations, Foreign Tax Credit Disallowance Under Section 965(g), Consolidated Groups, Hybrid Arrangements and Certain Payments Under Section 951A (RINs: 1545-BP21; 1545-BP22). We received the rule on November 2, 2020. It was published in the Federal Register as final and temporary regulations and removal of temporary regulations on November 12, 2020.1 85 Fed. Reg. 71998. The stated effective date of the rule is January 11, 2021. According to IRS, this final rule provides guidance relating to the allocation and apportionment of deductions and creditable foreign taxes, the definition of financial services income, foreign tax redeterminations, availability of foreign tax credits under the transition tax, and the application of the foreign tax credit limitation to consolidated groups. Also, according to IRS, the rule provides guidance related to adjustments to hybrid deduction accounts to take into account certain inclusions in income by a United States shareholder, conduit financing arrangements involving hybrid instruments, and the treatment of certain payments under the global intangible low-taxed income provisions. 1 The due date for this major rule report was December 2, 2020. Due to a processing error on our part, we are delayed in our issuance of this report.

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