Anti-splitter rules finalized

The IRS issued regulations under Sec. 909 regarding the foreign tax credit splitter rules. Under Sec. 909, if a foreign tax credit splitting event occurs with respect to a foreign income tax paid or accrued by a taxpayer, the taxpayer cannot take the foreign tax into account for federal income tax purposes before the tax year in which the taxpayer takes the related income into account (T.D. 9710). The new regulations finalize with a few minor clarifications the temporary regulations issued under Sec. 909 in 2012.

Included in the clarifications are changes to the definitions of reverse-hybrid splitter arrangements, loss-sharing splitter arrangements, and hybrid-instrument splitter arrangements and to the interim mechanical rules for tracking split taxes and related income. The preamble to the regulations notes that the regulations do not address other mechanical issues and that the IRS is still considering these issues and will address them in future guidance.

These final rules apply to tax years ending after Feb. 9, 2015.


Year-end tax planning and what’s new for 2016

Practitioners need to consider several tax planning opportunities to review with their clients before the end of the year. This report offers strategies for individuals and businesses, as well as recent federal tax law changes affecting this year’s tax returns.


News quiz: Retirement planning, tax practice, and fraud risk

Recent reports focused on a survey that gauges the worries about retirement among CPA financial planners’ clients, a suit that affects tax practitioners, and a guide that offers advice on fraud risk. See how much you know with this short quiz.


Bolster your data defenses

As you weather the dog days of summer, it’s a good time to make sure your cybersecurity structure can stand up to the heat of external and internal threats. Here are six steps to help shore up your systems.