Section 901(m) Covered Asset Acquisitions Guidance ‘Worth the Wait’

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Forthcoming guidance on covered asset acquisitions under tax code Section 901(m) will be “worth the wait,” a senior Treasury official says. Taxpayers have been eagerly awaiting the guidance, which implements a code section put in place to limit the availability of the foreign tax credit in these acquisitions. Speaking at an international tax conference sponsored by the Practising Law Institute, Ginny Chung, an attorney-adviser in Treasury's Office of Tax Policy, says the guidance is coming soon and is likely to be “very comprehensive and very detailed.”