The US Treasury Department and the Internal Revenue Service (IRS) have issued a notice requesting comments concerning the application of the separate basket limitation to dividends from non-controlled section 902 corporations under final regulations (TD 9452). The final regulations provide guidance on the foreign tax credit (FTC) treatment of dividends from non-controlled section 902 corporations. Non-controlled section 902 corporations are corporations in which a US taxpayer owns 10% or more of the voting stock, but which are not controlled foreign corporations (CFCs) because less than 50% of the overall stock is owned by 10% US shareholders. These corporations are also referred to...