Reg. § 1.909-0 Outline of regulation provisions for section 909.
This section lists the headings for through .
§ 1.909-1 Definitions and special rules.
(a) Definitions.
(b) Taxes paid or accrued by a partnership, S corporation or trust.
(c) Related income of a partnership, S corporation or trust.
(d) Application of section to pre-1987 accumulated profits and pre-1987 foreign income taxes.
(e) Effective/applicability date.
§ 1.909-2 Splitter arrangements.
(a) Foreign tax credit splitting event.
(1) In general.
(2) Split taxes not taken into account.
(b) Splitter arrangements.
(1) Reverse hybrid splitter arrangements.
(i) In general.
(ii) Split taxes from a reverse hybrid splitter arrangement.
(iii) Related income from a reverse hybrid splitter arrangement.
(iv) Reverse hybrid.
(v) Examples.
(2) Loss-sharing splitter arrangements.
(i) In general.
(ii) U.S. combined income group.
(iii) Income and shared loss of a U.S. combined income group.
(iv) Split taxes from a loss-sharing splitter arrangement.
(v) Related income from a loss-sharing splitter arrangement.
(vi) Foreign group relief or other loss-sharing regime.
(vii) Examples.
(3) Hybrid instrument splitter arrangements.
(i) U.S. equity hybrid instrument splitter arrangement.
(ii) U.S. debt hybrid instrument splitter arrangement.
(4) Partnership inter-branch payment splitter arrangements.
(i) In general.
(ii) Split taxes from a partnership inter-branch payment splitter arrangement.
(iii) Related income from a partnership inter-branch payment splitter arrangement.
(c) Effective/applicability date.
§ 1.909-3 Rules regarding related income and split taxes.
(a) Interim rules for identifying related income and split taxes.
(b) Split taxes on deductible disregarded payments.
(c) Effective/applicability date.
§ 1.909-4 Coordination rules.
(a) Interim rules.
(b) Effective/applicability date.
§ 1.909-5 2011 and 2012 splitter arrangements.
(a) Taxes paid or accrued in taxable years beginning in 2011.
(b) Taxes paid or accrued in certain taxable years beginning in 2012 with respect to a foreign consolidated group splitter arrangement.
(c) Effective/applicability date.
§ 1.909-6 Pre-2011 foreign tax credit splitting events.
(a) Foreign tax credit splitting event.
(1) In general.
(2) Taxes not subject to suspension under section .
(3) Taxes subject to suspension under section .
(b) Pre-2011 splitter arrangements.
(1) Reverse hybrid structure splitter arrangements.
(2) Foreign consolidated group splitter arrangements.
(3) Group relief or other loss-sharing regime splitter arrangements.
(i) In general.
(ii) Split taxes and related income.
(4) Hybrid instrument splitter arrangements.
(i) In general.
(ii) U.S. equity hybrid instrument splitter arrangement.
(iii) U.S. debt hybrid instrument splitter arrangement.
(c) General rules for applying section to pre-2011 split taxes and related income.
(1) Annual determination.
(2) Separate categories.
(d) Special rules regarding related income.
(1) Annual adjustments.
(2) Effect of separate limitation losses and deficits.
(3) Pro rata method for distributions out of earnings and profits that include both related income and other income.
(4) Alternative method for distributions out of earnings and profits that include both related income and other income.
(5) Distributions, deemed distributions, and inclusions out of related income.
(6) Carryover of related income.
(7) Related income taken into account by a section shareholder.
(8) Related income taken into account by a payor section corporation.
(9) Related income taken into account by an affiliated group of corporations that includes a section shareholder.
(10) Distributions of previously-taxed earnings and profits.
(e) Special rules regarding pre-2011 split taxes.
(1) Taxes deemed paid pro rata out of pre-2011 split taxes and other taxes.
(2) Pre-2011 split taxes deemed paid in pre-2011 taxable years.
(3) Carryover of pre-2011 split taxes.
(4) Determining when pre-2011 split taxes are no longer treated as pre-2011 split taxes.
(f) Rules relating to partnerships and trusts.
(1) Taxes paid or accrued by partnerships.
(2) Section allocations.
(3) Trusts.
(g) Interaction between section and other Code provisions.
(1) Section .
(2) Section .
(3) Section .
(4) Other foreign tax credit provisions.
(h) Effective/applicability date.
[T.D. 9710, 80 FR 7327, Feb. 10, 2015]