The Resource Partnership splitters

Partnership splitters

Partnership splitters
Partnership splitters
Section 909 was added to the Internal Revenue Code of 1986, as amended by P.L. 111-226, referred to as the Education, Jobs and Medicaid Assistance Act, signed into law by President Obama on 10 August 2010. The purpose of Code Sec. 909 is to prevent a taxpayer from claiming a credit (or a deduction) for foreign income taxes prior to the year in which the income to which such foreign income taxes relate is taken into account for U.S. federal income tax purposes. A separation or "split" of the U.S. foreign tax credit from the related income can occur when the liability for the foreign income is imposed on a different (albeit related) person than the person that takes into account the related income, as determined for U.S. federal income tax purposes. This article discusses the foreign tax credit and partnerships, Code Sec. 909 and partnerships, the scope of Code Sec. 909, allocation of creditable foreign tax expenditure (CFTEs), covered persons, guaranteed payments, and Code Sec. 704(c) allocations
Citation source
In: International tax journal. - Chicago. - Vol. 37 (2011), no. 6 (November-December) ; p. 7-12, 51-53
Osterberg, E.C. (Jr.)
Geographic coverage
Language note
  • partnership
  • foreign tax credit
Partnership splitters

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    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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