Comment Letter: Proposed Change to Section 901 Definition of Foreign Tax

Abstract:     
This letter comments on proposed regulations that would disallow foreign tax credits with respect to certain passive structure investments. The letter argues that the proposed regulations are not well-reasoned and should be substantially revised along the lines advocated in the letter.

Number of Pages in PDF File: 10

Keywords: foreign tax credits, foreign tax credit generator transactions, passive structured investments

Accepted Paper Series