Current year tax.
(4) Current year tax. The term current year tax means a foreign income tax that is paid or accrued by a controlled foreign corporation in a current taxable year (taking into account any adjustments resulting from a foreign tax redetermination (as defined in 1.9053(a)). See 1.9051 for rules on when foreign income taxes are considered paid or accrued for foreign tax credit purposes; see also 1.367(b)-7(g) for rules relating to foreign income taxes associated with foreign section 381 transactions and hovering deficits.