Guidance Related to the Foreign Tax Credit, Including Guidance Implementing Changes Made by the Tax Cuts and Jobs Act

This document contains proposed regulations that provide guidance relating to the determination of the foreign tax credit under the Internal Revenue Code (the ``Code''). The guidance relates to changes made to the applicable law by the Tax Cuts and Jobs Act (the ``Act''), which was enacted on December 22, 2017. Guidance on other foreign tax credit issues, including in relation to pre-Act statutory amendments, is also included in this document. The proposed regulations provide guidance needed to comply with statutory changes and affect individuals and corporations claiming foreign tax credits.