SECTION 8. REQUEST FOR

COMMENTS AND CONTACT INFORMATION

The Treasury Department and IRS solicit comments on the rules described in this notice, including specifically the extent to which the 2006 proposed regulations should be finalized and §1.704–1(b)(4)(viii)( d ) and §1.704–1(b)(5), Example 24 should be modified. The Treasury Department and IRS expect future guidance will treat pre-2011 splitter arrangements as giving rise to foreign tax credit splitting events in post-2010 taxable years. The Treasury Department and IRS request comments on the appropriateness of such treatment and whether and to what extent other