Limitation on Use of Deconsolidation To Avoid Foreign Tax Credit Limitations
other · IRS · Rule · Published 1995-11-07 · Effective 1994-01-01 · 60 FR 56117
Document
Document number
95-27563
Federal Register citation
60 FR 56117
CFR reference
26 CFR 1
Type
Rule
Action
Final regulations.
Category
other
Sub-agency
IRS
Publication date
1995-11-07
Effective date
1994-01-01
Treasury docket
TD 8627
Abstract
This document contains final regulations relating to certain limitations on the amount of the foreign tax credit under section 904(i). The final regulations will affect the sourcing and foreign tax credit separate limitation character of income for purposes of the calculation of the foreign tax credit by certain related domestic corporations. The final regulations are necessary to prevent avoidance of the foreign tax credit limitations.