03 February 2016 IRS issues regulations on partnership allocations of creditable foreign taxes The IRS has issued final and temporary (TD 9748), as well as proposed (REG-100861-15), regulations providing guidance on the allocation by a partnership of creditable foreign tax expenditures under Section 704. The regulations revise and clarify the operation of an existing safe harbor used to determine whether allocations of creditable foreign tax expenditures are deemed to be in accordance with the partners' interests in the partnership. Generally, subject to certain special rules, the temporary regulations are effective for partnership tax years that begin on or after January 1, 2016, and end on or after the date the regulations are published in the Federal Register. A Tax Alert on the regulations is forthcoming. Document ID: 2016-9002 |
