(3) The term payor means a person that pays or accrues a foreign income tax within the meaning of 1.901-2(f), and also includes a person that takes foreign income taxes paid or accrued by a partnership, S corporation, estate or trust into account pursuant to section 702(a)(6), section 901(b)(5) or section 1373(a).


26 CFR § 1.909-1

Scoping language

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