Back-to-Back Computer Licensing Arrangement Not Subject to Sec. 901(l)

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This article analyzes Notice 2005-90. In that Notice, the IRS addressed fears that IRC Section 901(l) would prevent taxpayers from claiming foreign tax credits for foreign withholding taxes incurred on income derived through standard back-to-back computer program licensing arrangements in which the recipient of income is required to make related payments with respect to positions in substantially similar or related property.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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