Determining the Amount of Taxes Paid for Purposes of the Foreign Tax Credit; Correction

الملخص

This document contains a correction to final and temporary regulations (TD 9535), that were published in the Federal Register on Monday, July 18, 2011. These regulations provide guidance relating to the determination of the amount of taxes paid for purposes of the foreign tax credit. These regulations address certain highly structured transactions that produce inappropriate foreign tax credit results. The regulations affect individuals and corporations that claim direct and indirect foreign tax credits.