IRS RULE CHANGE

摘要

The US Internal Revenue Service (IRS) has issued a ruling that the remittance basis charge (RBC) will be creditable against US tax, under Section 901, when combined with the remittance basis of taxation. This clarifies the earlier uncertainty surrounding the treatment of the RBC for US double taxation purposes. The former position of the IRS is outlined in a previous tax flash, which suggested that the RBC may not be creditable unless the income nominated against the charge was subject to US income tax.