Daily Tax Update - December 6, 2016: IRS Issues Temporary Regulations on Covered Asset Acquisitions

IRS Issues Temporary Regulations on Covered Asset Acquisitions:  Today, Treasury and the IRS issued temporary and proposed regulations, addressing transactions that generally are treated as asset acquisitions for US income tax purposes but treated as stock acquisitions or disregarded for foreign income tax purposes.  The rules limit the ability of taxpayers who buy and sell foreign assets in transactions designed to get around tax code section 901(m) to claim foreign tax credit through deals involving “covered asset acquisitions.”