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Responding to advocacy from the Chamber and its Brazil–U.S. Business Council (BUSBC), the U.S. Treasury Department and IRS recently provided taxpayers with welcome, temporary relief from some of the harshest aspects of the 2022 final foreign tax credit regulations—including the restrictive cost recovery and attribution requirements. This temporary reprieve from the 2022 regulations’ attribution requirement, of which the controversial new arm’s length requirement is a component, likely allows U.S. taxpayers to claim the foreign tax credit for income taxes paid to Brazil in 2022 and 2023. Treasury and the IRS also indicated that they may extend this relief to future years as they study the issue further. Months of Advocacy: As part of sustained, bilateral advocacy efforts on this issue, the Chamber and BUSBC in December issued a letter to Treasury seeking the immediate withdrawal, suspension, or modification of the new arm’s length requirement in the 20

Renata vasconsellosWatsonm mcleishWatson mcleishBrazilian ministry of economyUs treasury departmentUs cuba business councilMinistry of developmentBrazil us business councilOrganisation for economicUs chamberUs business councilUnited stateTwo capitalsBrazilian ministryEconomic co operationTax policy