Rocco Femia Quoted on Proportional Ownership of Partnership Assets in Tax Notes Today

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Tax Notes Today
02.02.15Rocco Femia was quoted discussing the rules for determining indirect foreign tax credits in the context of investments through partnerships. His remarks were made during a panel discussion on "Foreign Activities of U.S. Taxpayers" at the American Bar Association Section of Taxation meeting on January 30, 2015. Femia said the enactment of section 902(c)(7) in 2004 provided helpful clarification, but left other issues open.
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