US | Wyden-Portman proposal would disallow foreign tax credits and other US tax benefits connected with operations in Russia or Belarus

Executive summary

On 7 April 2022, United States (US) Senate Finance Committee Chairman Ron Wyden and Senate Finance Committee Member Rob Portman released a discussion draft of proposed legislation that would disallow foreign tax credits for taxes paid to Russia or Belarus, and would also disallow certain other US tax benefits (Proposal). In particular, the Proposal would amend Internal Revenue Code¹ Section 901(j) to deny foreign tax credits for taxes paid or accrued to Russia or Belarus. T…