Two recent sets of temporary regulations provide guidance for changes to the foreign tax credit rules made by the 2004 American Jobs Creation Act (AJCA). The 2004 AJCA, inter alia, reduced the number of foreign tax credit separate limitation categories and enacted overall domestic loss recapture rules. The temporary regulations require immediate attention, as certain provisions have retroactive effect and will significantly affect foreign tax credit computations for calendar 2007 tax years.

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