Foreign Tax Credit

Sections

• 1.901-1
  § 1.901-1 Allowance of credit for foreign income taxes.
• 1.901-2
  § 1.901-2 Income, war profits, or excess profits tax paid or accrued.
• 1.901-2A
  § 1.901-2A Dual capacity taxpayers.
• 1.901-3
  § 1.901-3 Reduction in amount of foreign taxes on foreign mineral income allowed as a credit.
• 1.901(j)-1
  § 1.901(j)-1 Denial of foreign tax credit with respect to certain foreign countries.
• 1.901(m)-1
  § 1.901(m)-1 Definitions.
• 1.901(m)-2
  § 1.901(m)-2 Covered asset acquisitions and relevant foreign assets.
• 1.901(m)-3
  § 1.901(m)-3 Disqualified tax amount and aggregate basis difference carryover.
• 1.901(m)-4
  § 1.901(m)-4 Determination of basis difference.
• 1.901(m)-5
  § 1.901(m)-5 Basis difference taken into account.
• 1.901(m)-6
  § 1.901(m)-6 Successor rules.
• 1.901(m)-7
  § 1.901(m)-7 De minimis rules.
• 1.901(m)-8
  § 1.901(m)-8 Miscellaneous.
• 1.902-0
  § 1.902-0 Outline of regulations provisions for section 902.
• 1.902-1
  § 1.902-1 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation.
• 1.902-2
  § 1.902-2 Treatment of deficits in post-1986 undistributed earnings and pre-1987 accumulated profits of a first- or lower-tier corporation for purposes of computing an amount of foreign taxes deemed paid under § 1.902-1.
• 1.902-3
  § 1.902-3 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid with respect to accumulated profits of taxable years of the foreign corporation beginning before January 1, 1987.
• 1.902-4
  § 1.902-4 Rules for distributions attributable to accumulated profits for taxable years in which a first-tier corporation was a less developed country corporation.
• 1.903-1
  § 1.903-1 Taxes in lieu of income taxes.
• 1.904-1
  § 1.904-1 Limitation on credit for foreign income taxes.
• 1.904-2
  § 1.904-2 Carryback and carryover of unused foreign tax.
• 1.904-3
  § 1.904-3 Carryback and carryover of unused foreign tax by spouses making a joint return.
• 1.904-4
  § 1.904-4 Separate application of section 904 with respect to certain categories of income.
• 1.904-5
  § 1.904-5 Look-through rules as applied to controlled foreign corporations and other entities.
• 1.904-6
  § 1.904-6 Allocation and apportionment of foreign income taxes.
• 1.904-7
  § 1.904-7 Transition rules.
• 1.904(b)-0
  § 1.904(b)-0 Outline of regulation provisions.
• 1.904(b)-1
  § 1.904(b)-1 Special rules for capital gains and losses.
• 1.904(b)-2
  § 1.904(b)-2 Special rules for application of section 904(b) to alternative minimum tax foreign tax credit.
• 1.904(b)-3
  § 1.904(b)-3 Disregard of certain dividends and deductions under section 904(b)(4).
• 1.904(f)-0
  § 1.904(f)-0 Outline of regulation provisions.
• 1.904(f)-1
  § 1.904(f)-1 Overall foreign loss and the overall foreign loss account.
• 1.904(f)-2
  § 1.904(f)-2 Recapture of overall foreign losses.
• 1.904(f)-3
  § 1.904(f)-3 Allocation of net operating losses and net capital losses.
• 1.904(f)-4
  § 1.904(f)-4 Recapture of foreign losses out of accumulation distributions from a foreign trust.
• 1.904(f)-5
  § 1.904(f)-5 Special rules for recapture of overall foreign losses of a domestic trust.
• 1.904(f)-6
  § 1.904(f)-6 Transitional rule for recapture of FORI and general limitation overall foreign losses incurred in taxable years beginning before January 1, 1983, from foreign source taxable income subject to the general limitation in taxable years beginning after December 31, 1982.
• 1.904(f)-7
  § 1.904(f)-7 Separate limitation loss and the separate limitation loss account.
• 1.904(f)-8
  § 1.904(f)-8 Recapture of separate limitation loss accounts.
• 1.904(f)-9 - 1.904(f)-11
  §§ 1.904(f)-9-1.904(f)-11 [Reserved]
• 1.904(f)-12
  § 1.904(f)-12 Transition rules.
• 1.904(g)-0
  § 1.904(g)-0 Outline of regulation provisions.
• 1.904(g)-1
  § 1.904(g)-1 Overall domestic loss and the overall domestic loss account.
• 1.904(g)-2
  § 1.904(g)-2 Recapture of overall domestic losses.
• 1.904(g)-3
  § 1.904(g)-3 Ordering rules for the allocation of net operating losses, net capital losses, U.S. source losses, and separate limitation losses, and for the recapture of separate limitation losses, overall foreign losses, and overall domestic losses.
• 1.904(i)-0
  § 1.904(i)-0 Outline of regulation provisions.
• 1.904(i)-1
  § 1.904(i)-1 Limitation on use of deconsolidation to avoid foreign tax credit limitations.
• 1.904(j)-0
  § 1.904(j)-0 Outline of regulation provisions.
• 1.904(j)-1
  § 1.904(j)-1 Certain individuals exempt from foreign tax credit limitation.
• 1.905-1
  § 1.905-1 When credit for foreign income taxes may be taken.
• 1.905-2
  § 1.905-2 Conditions of allowance of credit.
• 1.905-3
  § 1.905-3 Adjustments to U.S. tax liability and to current earnings and profits as a result of a foreign tax redetermination.
• 1.905-4
  § 1.905-4 Notification of foreign tax redetermination.
• 1.905-5
  § 1.905-5 Foreign tax redeterminations of foreign corporations that relate to taxable years of the foreign corporation beginning before January 1, 2018.
• 1.907-0
  § 1.907-0 Outline of regulation provisions for section 907.
• 1.907(a)-0
  § 1.907(a)-0 Introduction (for taxable years beginning after December 31, 1982).
• 1.907(a)-1
  § 1.907(a)-1 Reduction in taxes paid on FOGEI (for taxable years beginning after December 31, 1982).
• 1.907(b)-1
  § 1.907(b)-1 Reduction of creditable FORI taxes (for taxable years beginning after December 31, 1982).
• 1.907(c)-1
  § 1.907(c)-1 Definitions relating to FOGEI and FORI (for taxable years beginning after December 31, 1982).
• 1.907(c)-2
  § 1.907(c)-2 Section 907(c)(3) items (for taxable years beginning after December 31, 1982).
• 1.907(c)-3
  § 1.907(c)-3 FOGEI and FORI taxes (for taxable years beginning after December 31, 1982).
• 1.907(d)-1
  § 1.907(d)-1 Disregard of posted prices for purposes of chapter 1 of the Code (for taxable years beginning after December 31, 1982).
• 1.907(e)-1
  § 1.907(e)-1 [Reserved]
• 1.907(f)-1
  § 1.907(f)-1 Carryback and carryover of credits disallowed by section 907(a) (for amounts carried between taxable years that each begin after December 31, 1982).