US IRS publishes final regulations on foreign tax credit splitting

US IRS on February 10 published final regulations on foreign tax credit splitting events, clarifying aspects of the proposed and temporary regulations’ definitions of splitter arrangements and clarifying mechanical rules for tracking split taxes and related income.

The government said it will address additional mechanical issues associated with tracking related income and split taxes in future guidance.

The regulations replace temporary and proposed regulations under sections 909 and 704, released February 14, 2012.

The guidance implements legislation enacted August 10, 2010, which suspends the use of foreign tax credits until the related income is taken into account by the entity.

See:

• Foreign Tax Credit Splitting Events (TD 9710)