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back to index backAMERItalk September,  2016


Notice 2016-52: Foreign tax credit related to foreign-initiated adjustments

The IRS today released an advance version of Notice 2016-52, adding two new categories of transactions to arrangements treated as foreign tax credit splitter arrangements” under Code section 909. The transactions involve distributions of earnings by, or restructurings of certain foreign corporations (section 902 corporations”) in order to separate earnings from foreign taxes paid in a later year as a result of a foreign initiated adjustment that results in an assessment of additional tax on prior year earnings.

The amount of additional foreign income taxes paid must be greater than $10 million.  

Notice 2016-52 [PDF 64 KB] applies to foreign income taxes paid on or after September 15, 2016.


Source: KPMG U.S. - GAI





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