Advertisement
Topics

Tax Court Weighs In on STARS Transaction

The Tax Court held that a bank was not entitled to the tax benefits generated by a STARS transaction because the transaction lacked economic substance.

Regs. on Foreign Tax Credit Splitter Arrangements

The IRS issued regulations on determining who has the legal liability to pay the foreign tax for foreign tax credit purposes and on the application of the “anti-splitter” rules of Sec. 909.  

Congress Votes to Limit Use of Foreign Tax Credits

P.L. 111-226 makes changes to how corporations can use the foreign tax credit and also terminates the advance refundability of the earned income credit (under Sec. 3507), effective for tax years beginning after December 31, 2010.