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New Foreign Tax Credit Anti-Splitting Rule
Caplin & Drysdale

New Foreign Tax Credit Anti-Splitting Rule

Date: 11/8/2010

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In a foreign tax credit splitting event, newly enacted section 909 essentially defers FTCs until the related income is taken into account. Section 909’s interpretation poses some challenges, especially in identifying the related income. Click on the pdf icon to read the full version of the article.

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