10/50 basket going going...but not gone

The Treasury and the IRS did a commendable job in Notice 2003-5 of resolving many transitional issues relating to the differing treatment of pre-2003 and post-2002 10/50 dividends and the impact of these rules on the foreign tax credit regime. However, there is little simple about these transition r...

Full description

Saved in:
Bibliographic Details
Published in:Journal of International Taxation 2003-08, Vol.14 (8), p.4
Main Authors: Fischl, Alan L, Collins, Martin J
Format: Article
Language:English
Subjects:
Allocations
Baskets
Controlled foreign corporations
Dividend distributions
Dividends
Foreign tax credits
Internal Revenue Code
International taxation
Multinational corporations
Passive foreign investment companies
Redistricting
Regulation
Section 904(d)
Stockholders
Tax credits
Tax legislation
Tax rates
Transition rules
Online Access:Get full text
Tags: Add Tag
No Tags, Be the first to tag this record!
Description
Summary:The Treasury and the IRS did a commendable job in Notice 2003-5 of resolving many transitional issues relating to the differing treatment of pre-2003 and post-2002 10/50 dividends and the impact of these rules on the foreign tax credit regime. However, there is little simple about these transition rules. Notice 2003-5 provides guidance on several transitional issues: 1. application of look-through rules to dividends paid by 10/50 corporations in post-2002 tax years, 2. treatment of distributions out of pre-acquisition earnings, 3. ordering rules for post-2002 distributions from 10/50 corporations, 4. allocation and apportionment of expenses of 10/50 corporations not that look-through will apply, 5. applicability of tax accounting elections to 10/50 corporations now that look-through will apply, 6. look-through treatment of dividends paid by some lower-tier 10/50 corporations, 7. carryover and carryback of excess foreign taxes, and 8. recapture of a separate limitation loss arising in other baskets.
ISSN:1049-6378