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Tax
Tax News & Views
February 17, 2012
International Tax Alert: IRS issues foreign tax credit splitter guidance, technical taxpayer rules
The Internal Revenue Service on February 9 filed temporary regulations (T.D. 9577) under section 909 addressing foreign tax credit splitter transactions and final regulations (T.D. 9576) providing guidance on determining who is considered the taxpayer of foreign taxes for purposes of the foreign tax credit. This Tax Alert from the International group in Deloitte Tax LLP's Washington National Tax practice describes some of the key aspects of these regulations.
— Michael DeHoff
Tax Policy Group
Deloitte Tax LLP
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