US Outbound: IRS releases new foreign tax credit regulations
01 July 2012
The Internal Revenue Service (IRS) and US Treasury Department recently released two sets of regulations addressing the foreign tax credit rules. The first set of regulations address the application of the section 909 foreign tax credit splitter rules to post-2010 taxable years (the section 909 regulations) (T.D. 9577). The second set of regulations provide guidance on who is considered to pay a foreign income tax for purposes of the foreign tax credit rules (the Section 901 regulations) (T.D. 9576).
The section 909 regulations
The section 909 regulations, which are temporary and proposed, provide much-needed guidance on the section 909 foreign tax credit splitter rules, which Congress enacted in August 2010 (for further information, please see our October 2010 column, President Obama Signs New International Tax Provisions Into Law). The section 909 regulations are generally...
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