Ivins Attorney Comments on Guidance under Section 909

Ivins, Phillips & Barker attorney John D. Bates was quoted several times in Tax Notes Today regarding upcoming guidance under the section 909 foreign tax credit splitter rules.  Guidance under section 909 was listed on the IRS and Treasury's priority guidance plan for 2010-2011, and government officials have indicated that it is coming in the next few months. The first round of guidance on section 909, Notice 2010-92, addressed the section's application to foreign taxes paid or accrued by a section 902 corporation in taxable years beginning on or before December 31, 2010.