News & Events
Main Menu

Nature Abhors a Splitter: The FTC Splitter and Indirect FTC Rules

PDF
02.14.2011
John D. Bates
Tax Notes

This report discusses the interaction of new section 909 with sections 902 and 960. It provides discrete recommendations for the coordination of these rules and responds to recent comments by policymakers suggesting that a related income first earnings and profits distribution ordering rule might not be available prospectively under section 909.

Back to Page