Business Services Industry
Final regs. on partnership allocations of CFTEs.(creditable foreign tax expenditures)
Tax Adviser, The, January, 2007 by Rollinson, Marjorie A.
The IRS issued final regulations (TD 9292, 10/19/06) under Sec. 704(b) that provide rules for the allocation of partnership creditable foreign taxes. They adopt the proposed and temporary regulations (TD 9121, 4/20/04), with substantial modifications.
Final Regs.
The final regulations retain the provisions of the proposed and temporary regulations excluding allocations of creditable foreign tax expenditures (CFTEs) from the substantial-economic-effect safe harbor of Regs. Sec. 1.704-1(b)(2), and provide a safe harbor under which allocations of CFTEs will be deemed to be in accordance with the partners' interests in the partnership (if CFTE allocations are in proportion to the distributive shares of income to which they relate). In comparison to the...
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