Application of Separate Limitations to Dividends From Noncontrolled Section 902 Corporations
other · IRS · Rule · Published 2009-06-11 · Effective 2009-06-11 · 74 FR 27868
Document
Document number
E9-13521
Federal Register citation
74 FR 27868
CFR reference
26 CFR 1
Type
Rule
Action
Final regulations, temporary regulations, and removal of temporary regulations.
Category
other
Sub-agency
IRS
Publication date
2009-06-11
Effective date
2009-06-11
Treasury docket
TD 9452
Abstract
This document contains final regulations regarding the application of separate foreign tax credit limitations to dividends received from noncontrolled section 902 corporations. The American Jobs Creation Act of 2004 (AJCA) modified the treatment of such dividends effective for taxable years beginning after December 31, 2002. The Gulf Opportunity Zone Act of 2005 (GOZA) permits taxpayers to elect to defer the effective date of the AJCA amendments until taxable years beginning after December 31, 2004. The final regulations provide guidance needed to comply with these changes and affect corporations claiming foreign tax credits.