Splitter Guidance May Include Multiyear Tracking Approach to Group Relief

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The government is considering whether to adopt a multiyear “tracking” approach to determining foreign income in group relief transactions as it works on more guidance on foreign tax credit splitter deals, a Treasury Department official says. It is among other approaches under new tax code Section 909 and is intended to stop taxpayers from splitting foreign taxes from the underlying income to inappropriately get the foreign tax credit.