FINAL FTC REGS. ON RELATED-PARTY RENTS AND ROYALTIES

The IRS has issued T.D. 9141, relating to foreign tax credit limitations, focusing in part on the treatment of related-party active rents and royalties. For purposes of computing foreign tax credit limitations under Section 904(d) separate limitation basketing, the final regulations adopt a proposal...

Full description

Saved in:
Bibliographic Details
Published in:Journal of International Taxation 2004-12, Vol.15 (12), p.5
Main Authors: Teunissen, Oscar, Nauheim, Steve
Format: Article
Language:English
Subjects:
Controlled foreign corporations
Federal court decisions
Foreign tax credits
Internal Revenue Code
International taxation
Leasing
Licensed products
Licenses
Marketing
Related party transactions
Rents
Royalties
Section 904(d)
Tax court decisions
Tax credits
Tax regulations
TD 9141
Online Access:Get full text
Tags: Add Tag
No Tags, Be the first to tag this record!
Description
Summary:The IRS has issued T.D. 9141, relating to foreign tax credit limitations, focusing in part on the treatment of related-party active rents and royalties. For purposes of computing foreign tax credit limitations under Section 904(d) separate limitation basketing, the final regulations adopt a proposal expanding the exception from passive income for active rents and royalties to include rents and royalties from related payors.
ISSN:1049-6378