Notice 2016-52 was published on 15 September 2016 announcing that the U.S. Treasury Department and the IRS intends to issue regulations under section 909 in relation to section 902 corporations that pay foreign income taxes resulting from foreign-initiated adjustments. The planned regulations are in response to foreign-initiated adjustments that may arise under European Union (EU) State aid law, to the extent EU State aid payments result in creditable foreign taxes. Specifically, before a payment is made pursuant to a foreign-initiated adjustment, a taxpayer may attempt to change its ownership structure or cause the section 902 corporation to make an extraordinary...