Washington (April 23, 2004) -- The Treasury Department and the Internal Revenue Service have issued temporary regulations requiring partnerships to allocate foreign taxes in the same manner as they allocate the income to which those taxes relate.
The regulations target certain transactions in which U.S. partners (or U.S. shareholders of partners that are controlled foreign corporations) attempt, through special partnership allocations, to claim foreign tax credits that aren't matched by income subject to U.S. tax.
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