Foreign income tax.

(5) Foreign income tax. The term foreign income tax means each separate levy (as defined in 1.901-2(d)) that is an income, war profits, and excess profits tax as defined in 1.901-2(a), and tax included in the term income, war profits, and excess profits tax by reason of section 903 and 1.903-1(a), that is imposed by a foreign country or a possession of the United States, including any such tax that is deemed paid by a controlled foreign corporation under section 960(b)(2). Income, war profits, and excess profits taxes do not include amounts excluded from the definition of those taxes under section 901. See, for example, section 901(f), (g), and (i). Foreign income tax also does not include taxes paid by a controlled foreign corporation for which a credit is disallowed at the level of the controlled foreign corporation. See, for example, sections 245A(e)(3), 901(k)(1), (l), and (m), 909, and 6038(c)(1)(B). Foreign income tax, however, includes tax that may be deemed paid but for which a credit is reduced or disallowed at the level of the United States shareholder. See, for example, sections 901(e), 901(j), 901(k)(2), 908, 965(g), and 6038(c)(1)(A).

Source

26 CFR § 1.960-1


Scoping language

None
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