Layla Asali Queries Treasury Official Queries Regarding Foreign Tax Credit Guidance in Tax Notes Today

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Tax Notes Today
09.22.14Layla Asali was mentioned in connection with a discussion of recent foreign tax credit guidance under section 901(m) during the September 19 American Bar Association's Taxation Section meeting in Denver. A Treasury spokesperson said comprehensive guidance will be released soon, but recent guidance (Notices 2014-44 and 2014-45) addressed certain dispositions. The panel discussed the effective date provisions of the Notices, and how they apply to retroactive check-the-box-elections. Asali asked the official what would happen if a taxpayer filed a check-the-box election on July 22 with a retroactive effective date. The Treasury spokesperson responded that for elections filed on July 22, it is yet to be determined whether they are subject to the spirit of the original Notice released on July 21.
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