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15 September 2016

IRS announces regulations that will apply Section 909 (foreign tax credit splitters) to certain transactions completed in advance of certain foreign-initiated tax payments

In Notice 2016-52, the IRS identifies as a foreign tax credit splitter arrangement under Section 909 certain transactions that are completed in advance of certain large foreign-initiated tax payments and have the effect of separating the foreign taxes from the related income. The notice specifically refers to payments under European Union state aid law that may result in creditable foreign taxes. The forthcoming regulations will apply to foreign income taxes paid on or after September 15, 2016. A Tax Alert is forthcoming.

Document ID: 2016-9007

 

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