February 5, 2026 – John Rose, Tax Director in Aprio’s National Professional Practice Group, explained how artificial intelligence (AI) is making it more difficult for companies to track and claim foreign tax credits tied to digital taxes in Bloomberg Law. As AI enables intellectual property and related activities to move seamlessly across borders, determining where income‑producing activity occurs has become increasingly complex, particularly under the IRS’s final foreign tax credit regulations
John outlined how the interaction between the IRS’s final regulations and prior rules can significantly impact a taxpayer’s ability to claim foreign tax credits, especially when expenses and development activities span multiple jurisdictions.
He highlighted the importance of carefully evaluating both regulatory frameworks, noting that IRS Notice 2023‑55 allows taxpayers to rely on the prior regulations in certain circumstances, potentially preserving creditability and mitigating unintended consequences in an AI‑driven global tax environment.
Read the full article on Bloomberg Law.