International Tax Issues Corner

Forst, David
July 2012
Journal of Passthrough Entities;Jul/Aug2012, Vol. 15 Issue 4, p17
Academic Journal
The article focuses on the foreign tax credit partnership of inter-branch payment splitter arrangements in the U.S. It notes that a splitting condition happens when the foreign tax paid by a partnership to a payment between disregarded branches of the partnership is not distributed to the partners in similar proportion as the distributive shares of income to which the inter-branch payment tax is designated. It mentions that the splitting event happens when a partner is given more foreign tax.


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