... [ Prop. Treas. Reg. §§ 1.892-4 and 1.892-5 ]... partly supplement and partly replace the current temporary regulations under IRC Section 892 that have been in place since 2002 (and earlier). Importantly, the proposed regulations...
By Diane L. Mutolo
INTRODUCTION: The Tax Relief Unemployment Insurance Reauthorization and Job Creation Act of 2010 amended IRC Section 2010(c) to allow, after December 31, 2010, a surviving spouse to increase his or her applicable exclusion amount...
As we know, Congress tinkered with the foreign tax credit (FTC) rules in 2010 in a number of ways. One of those changes was to add Section 901(m) (" Denial of foreign tax credit with respect to foreign income not subject to United States taxation...