FOGEI taxes.

(5) FOGEI taxes. If FOGEI is reduced pursuant to this paragraph (c) (and thereby recharacterized as non-FOGEI income), any foreign taxes imposed on the FOGEI that is recharacterized as other income retain their character as FOGEI taxes. See section 907(c)(5).


26 CFR § 1.907(c)-1

Scoping language

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