Limits the amount of credit available in each year, including carryback and carryover of credit. shareholders with 10% or greater voting interests in the distributor foreign corporation.Īllows direct credit for taxes (typically foreign withholding taxes based on gross receipts) paid in lieu of the generally imposed net income tax.
IRC 902 was repealed by the TCJA for tax years beginning after 2017, but is still effective for pre-2018 distributions to U.S. taxpayer based on realized net income.Īllows deemed paid or indirect credit for foreign taxes based on the proportion of taxes paid by a corporation on its distributed earnings and profits. Large Business and International (LB&I) and Small Business/Self Employed (SB/SE) personnelĭisallows any claim for FTCs with respect to any dividend for which a deduction is allowed under IRC 245A.ĭisallows any claim for FTCs with respect to hybrid dividends for which a deduction is not allowed under IRC 245A by IRC 245A(e).Īllows direct credit for taxes paid to a foreign country by a U.S. (3) Updated to reflect organizational and editorial changes.
IRC 951 CODE
Internal Revenue Code Sections Dealing with Foreign Taxes Other Statutory Provisions Addressing Eligibility for FTCĭenial of FTC Associated with Covered Asset AcquisitionsĬarryback and Carryover of Excess CreditsĮxpenses Related to Foreign Source IncomeĪlternative Minimum Tax Considerations for Pre-2018 Tax YearsĬomparison of Indirect Credit Computations for Pre-2018 Taxable Years Exhibit 4.61.10-4 Internal Revenue Code Sections Dealing with Foreign Taxesįoreign Tax Credit Examination Guidelines.Exhibit 4.61.10-3 Comparison of Indirect Credit Computations for Pre-2018 Taxable Years.Exhibit 4.61.10-2 Indirect Taxes Examination Techniques.Exhibit 4.61.10-1 Direct Taxes Examination Techniques.4.61.10.14 Alternative Minimum Tax Considerations for Pre-2018 Tax Years.4.61.10.13 Code Sections Affecting Credit for Foreign Taxes.4.61.10.12 General Examination Guidelines.
4.61.10.11.1 Expenses Related to Foreign Source Income.4.61.10.10.3 Statute of Limitations on Carryback Years.4.61.10.10.2 Carryback and Carryover of Excess Credits.4.61.10.10.1 Classifying Income into Categories.4.61.10.8.2 Effects of Exchange Fluctuations.4.61.10.8.1 Foreign Tax Redetermination Defined.4.61.10.8 Changes in the Amount of Foreign Taxes Claimed.4.61.10.4.8.2 Deemed Paid Credit Computation.4.61.10.4.8 Deemed Paid Credit Computation.4.61.10.4.7.3 Indirect Credit Examination Techniques.4.61.10.4.6 Payment or Accrual of the Foreign Tax.4.61.10.4.5 Denial of FTC Associated with Covered Asset Acquisitions.4.61.10.4.4 Denial of FTC for Certain Countries.4.61.10.4.3 Taxes "In Lieu of" Income Taxes.4.61.10.4.1 Credit Applicable Only to Taxes.4.61.10.3 Other Statutory Provisions Addressing Eligibility for FTC.4.61.10.2 Foreign Tax Credit Examination Guidelines.
0 kommentar(er)
