Public comments requested on US foreign tax credit treatment of certain foreign dividends

The US Treasury Department and the Internal Revenue Service (IRS) have issued a notice requesting comments concerning the application of the separate basket limitation to dividends from non-controlled section 902 corporations under final regulations (TD 9452). The final regulations provide guidance on the foreign tax credit (FTC) treatment of dividends from non-controlled section 902 corporations.
Non-controlled section 902 corporations are corporations in which a US taxpayer o…