Weil Tax BLOG - Feed https://tax.weil.com/contributor/ricardo-fernandez/ Views and developments from the Tax Department at Weil Thu, 05 Nov 2026 23:07:52 +0000 hourly 1 Proposed Treasury Regulations Address Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income https://tax.weil.com/insights/proposed-treasury-regulations-address-allocation-and-apportionment-of-deductions-to-foreign-source-section-951a-category-income-and-deduction-eligible-income/ Fri, 11 Sep 2026 14:37:16 +0000 Devon Bodoh George Vallejo Ricardo Fernandez https://tax.weil.com/?p=2694 On September 11, 2026, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations (REG-117273-25) under Sections 904(b)(5) and 250(b)(3) addressing the allocation and apportionment of deductions to foreign source Section 951A category income for foreign tax credit limitation purposes and the computation of deduction eligible income (“DEI”).1 The Proposed Regulations

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]]> On September 11, 2026, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations (REG-117273-25) under Sections 904(b)(5) and 250(b)(3) addressing the allocation and apportionment of deductions to foreign source Section 951A category income for foreign tax credit limitation purposes and the computation of deduction eligible income (“DEI”).1 The Proposed Regulations

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]]> IRS Releases Guidance to Clarify Corporate AMT Calculations https://tax.weil.com/insights/irs-releases-guidance-to-clarify-corporate-amt-calculations/ Wed, 27 Dec 2023 16:45:09 +0000 Devon Bodoh Andrew Piper Ricardo Fernandez https://tax.weil.com/?p=2078 The Inflation Reduction Act of 2022 (“IRA”) introduced a corporate alternative minimum tax (“CAMT”) on an “applicable corporation’s” (“Applicable Corporation”) financial statement income. The CAMT is applicable for taxable years beginning after December 31, 2022 and imposes a 15% minimum tax on a corporation’s “applicable financial statement income” (“AFSI”). To be an Applicable Corporation, a

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