Final regulations and removal of temporary regulations.
Category
tax-irs
Sub-agency
IRS
Publication date
2020-03-23
Effective date
2020-03-23
Treasury docket
TD 9895
Abstract
This document contains final Income Tax Regulations under section 901(m) of the Internal Revenue Code (Code) with respect to 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. These regulations are necessary to provide guidance on applying section 901(m). These regulations affect taxpayers claiming foreign tax credits.