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Few Changes in Final Rules on Foreign Tax Credit Splitters

February 17, 2015 By Heather Ripley

On February 9, 2015, the U.S. Treasury released final regulations on foreign tax credit (FTC) splitting arrangements (the “2015 Regulations”). The final rules, released the same day that the 2012 temporary and proposed regulations were set to expire, offer some definitional and other clarifications and add useful illustrations. But for the most part, the 2015 Regulations adopt the prior proposed and temporary regulations, including the exclusive list of FTC splitter arrangements. Notably, the final rules fail to address several “mechanical issues” (i.e., issues concerning the tracking [...]Read more

Filed Under: International - Corporate Tax Planning, International - Inbound, International - Outbound, International Tax Advisory Tagged With: final regulations, foreign tax credit, foreign tax credit splitter, FTC, hybrid instrument, loss sharing, reverse hybrid, section 909

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