The International Tax Institute, Inc. holds monthly seminars in mid-town Manhattan on current subjects of international tax law.
We provide New York State continuing legal and professional education (non-transitional CLE and CPE) credits to international tax attorneys and accountants. Founded in 1961, we are a 501(c)(3) organization.
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Great complexity arises under the foreign tax credit rules when the U.S. tax base diverges from the foreign country base on which a foreign tax is imposed. Section 909 was aimed at specific “splitter” transactions that seek to exploit these inconsistencies to allow a U.S. taxpayer to claim credits for foreign taxes for which the U.S. taxpayer is technically liable under a foreign country’s tax law without including corresponding amounts of income. Section 909 “suspends” the foreign tax until the related income is taken into account by the U.S. taxpayer. However, the rules that track the “related” income and determine when it is treated as taken into account in some circumstances can have the practical effect of permanently eliminating credits for the foreign tax.
The Panel will discuss the final regulations under Section 909, the types of transactions to which the rules apply and the difficulties that may arise in “freeing up” suspended foreign taxes, also touching on the relationship between section 909, the “technical taxpayer” rule and the “compulsory payment” requirements.
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Bryan Cave LLP
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International Business Company Formation, Inc.
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Morrison & Foerster LLP
Osler, Hoskin & Harcourt LLP
PKF O'Connor Davies
Proskauer Rose LLP
Roberts & Holland LLP
Skadden, Arps, Slate, Meagher & Flom LLP
Sullivan & Cromwell LLP
Viacom International, Inc.
Weil, Gotshal & Manges LLP
Winston & Strawn LLP