§ 1.901-1 Allowance of credit for foreign income taxes
§ 1.901-2 Income, war profits, or excess profits tax paid or accrued
§ 1.901-2A Dual capacity taxpayers
§ 1.901-3 Reduction in amount of foreign taxes on foreign mineral income allowed as a credit
§ 1.901(j)-1 Denial of foreign tax credit with respect to certain foreign countries
§ 1.901(m)-1 Definitions
§ 1.901(m)-2 Covered asset acquisitions and relevant foreign assets
§ 1.901(m)-3 Disqualified tax amount and aggregate basis difference carryover
§ 1.901(m)-4 Determination of basis difference
§ 1.901(m)-5 Basis difference taken into account
§ 1.901(m)-6 Successor rules
§ 1.901(m)-7 De minimis rules
§ 1.901(m)-8 Miscellaneous
§ 1.902-0 Outline of regulations provisions for section 902
§ 1.902-1 Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation
§ 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 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 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 Taxes in lieu of income taxes
§ 1.904-1 Limitation on credit for foreign income taxes
§ 1.904-2 Carryback and carryover of unused foreign tax
§ 1.904-3 Carryback and carryover of unused foreign tax by spouses making a joint return
§ 1.904-4 Separate application of section 904 with respect to certain categories of income
§ 1.904-5 Look-through rules as applied to controlled foreign corporations and other entities
§ 1.904-6 Allocation and apportionment of foreign income taxes
§ 1.904-7 Transition rules
§ 1.904(b)-0 Outline of regulation provisions
§ 1.904(b)-1 Special rules for capital gains and losses
§ 1.904(b)-2 Special rules for application of section 904(b) to alternative minimum tax foreign tax credit
§ 1.904(b)-3 Disregard of certain dividends and deductions under section 904(b)(4)
§ 1.904(f)-0 Outline of regulation provisions
§ 1.904(f)-1 Overall foreign loss and the overall foreign loss account
§ 1.904(f)-2 Recapture of overall foreign losses
§ 1.904(f)-3 Allocation of net operating losses and net capital losses
§ 1.904(f)-4 Recapture of foreign losses out of accumulation distributions from a foreign trust
§ 1.904(f)-5 Special rules for recapture of overall foreign losses of a domestic trust
§ 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 beg
§ 1.904(f)-7 Separate limitation loss and the separate limitation loss account
§ 1.904(f)-8 Recapture of separate limitation loss accounts
§ 1.904(f)-12 Transition rules
§ 1.904(g)-0 Outline of regulation provisions
§ 1.904(g)-1 Overall domestic loss and the overall domestic loss account
§ 1.904(g)-2 Recapture of overall domestic losses
§ 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 Outline of regulation provisions
§ 1.904(i)-1 Limitation on use of deconsolidation to avoid foreign tax credit limitations
§ 1.904(j)-0 Outline of regulation provisions
§ 1.904(j)-1 Certain individuals exempt from foreign tax credit limitation
§ 1.905-1 When credit for foreign income taxes may be taken
§ 1.905-2 Conditions of allowance of credit
§ 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 Notification of foreign tax redetermination
§ 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 Outline of regulation provisions for section 907
§ 1.907(a)-0 Introduction (for taxable years beginning after December 31, 1982)
§ 1.907(a)-1 Reduction in taxes paid on FOGEI (for taxable years beginning after December 31, 1982)
§ 1.907(b)-1 Reduction of creditable FORI taxes (for taxable years beginning after December 31, 1982)
§ 1.907(c)-1 Definitions relating to FOGEI and FORI (for taxable years beginning after December 31, 1982)
§ 1.907(c)-2 Section 907(c)(3) items (for taxable years beginning after December 31, 1982)
§ 1.907(c)-3 FOGEI and FORI taxes (for taxable years beginning after December 31, 1982)
§ 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(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)

Terms Used In CFR > Title 26 > Chapter I > Subchapter A > Part 1 > foreign tax credit

  • Amendment: A proposal to alter the text of a pending bill or other measure by striking out some of it, by inserting new language, or both. Before an amendment becomes part of the measure, thelegislature must agree to it.
  • Amortization: Paying off a loan by regular installments.
  • Appeal: A request made after a trial, asking another court (usually the court of appeals) to decide whether the trial was conducted properly. To make such a request is "to appeal" or "to take an appeal." One who appeals is called the appellant.
  • Appropriation: The provision of funds, through an annual appropriations act or a permanent law, for federal agencies to make payments out of the Treasury for specified purposes. The formal federal spending process consists of two sequential steps: authorization
  • Assets: (1) The property comprising the estate of a deceased person, or (2) the property in a trust account.
  • Attachment: A procedure by which a person's property is seized to pay judgments levied by the court.
  • Beneficiary: A person who is entitled to receive the benefits or proceeds of a will, trust, insurance policy, retirement plan, annuity, or other contract. Source: OCC
  • Case law: The law as laid down in cases that have been decided in the decisions of the courts.
  • Contract: A legal written agreement that becomes binding when signed.
  • Corporation: A legal entity owned by the holders of shares of stock that have been issued, and that can own, receive, and transfer property, and carry on business in its own name.
  • corporation: includes associations, joint-stock companies, and insurance companies. See 26 CFR 36.3121(l)(1)-1
  • Dependent: A person dependent for support upon another.
  • Discovery: Lawyers' examination, before trial, of facts and documents in possession of the opponents to help the lawyers prepare for trial.
  • domestic: when applied to a corporation * * * means created or organized in the United States or under the law of the United States or of any State or Territory. See 26 CFR 36.3121(l)(1)-1
  • Donor: The person who makes a gift.
  • Entitlement: A Federal program or provision of law that requires payments to any person or unit of government that meets the eligibility criteria established by law. Entitlements constitute a binding obligation on the part of the Federal Government, and eligible recipients have legal recourse if the obligation is not fulfilled. Social Security and veterans' compensation and pensions are examples of entitlement programs.
  • Equitable: Pertaining to civil suits in "equity" rather than in "law." In English legal history, the courts of "law" could order the payment of damages and could afford no other remedy. See damages. A separate court of "equity" could order someone to do something or to cease to do something. See, e.g., injunction. In American jurisprudence, the federal courts have both legal and equitable power, but the distinction is still an important one. For example, a trial by jury is normally available in "law" cases but not in "equity" cases. Source: U.S. Courts
  • Evidence: Information presented in testimony or in documents that is used to persuade the fact finder (judge or jury) to decide the case for one side or the other.
  • Fair market value: The price at which an asset would change hands in a transaction between a willing, informed buyer and a willing, informed seller.
  • Fiduciary: A trustee, executor, or administrator.
  • Fiscal year: The fiscal year is the accounting period for the government. For the federal government, this begins on October 1 and ends on September 30. The fiscal year is designated by the calendar year in which it ends; for example, fiscal year 2006 begins on October 1, 2005 and ends on September 30, 2006.
  • Fixed Rate: Having a "fixed" rate means that the APR doesn't change based on fluctuations of some external rate (such as the "Prime Rate"). In other words, a fixed rate is a rate that is not a variable rate. A fixed APR can change over time, in several circumstances:
    • You are late making a payment or commit some other default, triggering an increase to a penalty rate
    • The bank changes the terms of your account and you do not reject the change.
    • The rate expires (if the rate was fixed for only a certain period of time).
  • Foreclosure: A legal process in which property that is collateral or security for a loan may be sold to help repay the loan when the loan is in default. Source: OCC
  • foreign: when applied to a corporation * * * means a corporation * * * which is not domestic. See 26 CFR 36.3121(l)(1)-1
  • Freedom of Information Act: A federal law that mandates that all the records created and kept by federal agencies in the executive branch of government must be open for public inspection and copying. The only exceptions are those records that fall into one of nine exempted categories listed in the statute. Source: OCC
  • Gift: A voluntary transfer or conveyance of property without consideration, or for less than full and adequate consideration based on fair market value.
  • Grantor: The person who establishes a trust and places property into it.
  • Intangible property: Property that has no intrinsic value, but is merely the evidence of value such as stock certificates, bonds, and promissory notes.
  • Interest rate: The amount paid by a borrower to a lender in exchange for the use of the lender's money for a certain period of time. Interest is paid on loans or on debt instruments, such as notes or bonds, either at regular intervals or as part of a lump sum payment when the issue matures. Source: OCC
  • Jurisdiction: (1) The legal authority of a court to hear and decide a case. Concurrent jurisdiction exists when two courts have simultaneous responsibility for the same case. (2) The geographic area over which the court has authority to decide cases.
  • Lease: A contract transferring the use of property or occupancy of land, space, structures, or equipment in consideration of a payment (e.g., rent). Source: OCC
  • Liabilities: The aggregate of all debts and other legal obligations of a particular person or legal entity.
  • Lien: A claim against real or personal property in satisfaction of a debt.
  • Mortgage: The written agreement pledging property to a creditor as collateral for a loan.
  • Obligation: An order placed, contract awarded, service received, or similar transaction during a given period that will require payments during the same or a future period.
  • Partnership: A voluntary contract between two or more persons to pool some or all of their assets into a business, with the agreement that there will be a proportional sharing of profits and losses.
  • Personal property: All property that is not real property.
  • Precedent: A court decision in an earlier case with facts and law similar to a dispute currently before a court. Precedent will ordinarily govern the decision of a later similar case, unless a party can show that it was wrongly decided or that it differed in some significant way.
  • Public law: A public bill or joint resolution that has passed both chambers and been enacted into law. Public laws have general applicability nationwide.
  • Real property: Land, and all immovable fixtures erected on, growing on, or affixed to the land.
  • Remainder: An interest in property that takes effect in the future at a specified time or after the occurrence of some event, such as the death of a life tenant.
  • Settlement: Parties to a lawsuit resolve their difference without having a trial. Settlements often involve the payment of compensation by one party in satisfaction of the other party's claims.
  • Statute: A law passed by a legislature.
  • Statute of limitations: A law that sets the time within which parties must take action to enforce their rights.
  • stock: includes shares in an association, joint-stock company, or insurance company. See 26 CFR 36.3121(l)(8)-1