Rocco Femia is quoted on various aspects of the recently-released IRS guidance on the new section 909 foreign tax credit splitter rules. The guidance relates to the application of the rules to foreign income taxes paid or accrued by section 902 corporations before January 1, 2011. "It's important for the multinational community to have certainty when they're considering their year-end tax planning," Femia said. "The government came through and should be commended for its timeliness."