Charts of Examples in Notice 2014-44

Last week the IRS released Notice 2014-44, announcing that regulations will be issued under Code §901(m). Code §901(m)(1) provides that, in the case of a covered asset acquisition ("CAA"), the disqualified portion of any foreign income tax determined with respect to the income or gain attributable to relevant foreign assets ("RFAs") will not be taken into account in determining the foreign tax credit allowed under Code §901(a), and in the case of foreign income tax... Read more →