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In December 2016, the Internal Revenue Service and Treasury Department issued long awaited proposed and temporary regulations under section 901(m) regarding "covered asset acquisitions." Covered asset acquisitions are transactions that generally are treated as asset acquisitions for U.S. income tax purposes and either are treated as stock acquisitions or are disregarded for foreign income tax purposes. The new regulations provide much needed guidance on the application of section 901(m) to limit the ability of taxpayers to claim a foreign tax credit in certain circumstances. This webinar will review the regulations, discuss any traps for the unwary that may be lurking in the regulatory detail, and provide practical considerations for compliance.
There are no classes scheduled at this time for this course.
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