Internal Revenue Bulletin: 2008-16
April 21, 2008
This document contains corrections to final and temporary regulations (T.D. 9368, 2008-6 I.R.B. 382) regarding the reduction of the number of separate foreign tax credit limitation categories under section 904(d) of the Code. The regulations affect taxpayers claiming foreign tax credits and provide guidance needed to comply with the statutory changes made by the American Jobs Creation Act of 2004 (AJCA).
This document contains a correction to final regulations (T.D. 9273, 2006-2 C.B. 394) addressing the carryover of certain tax attributes, such as earnings and profits and foreign income tax accounts, when two corporations combine in a corporate reorganization or liquidation that is described in both sections 367(b) and 381 of the Code.
This document cancels a public hearing on proposed regulations (REG-114126-07, 2008-6 I.R.B. 410) that provide guidance relating to the reduction of the number of separate foreign tax credit limitation categories under section 904(d) of the Code.
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