IRS Practice Unit: Foreign Tax Credit General Principles (IRC §904)

Foreign tax credit (FTC) general principles after the 2017 tax act, the IRS Large Business and International Concept Unit outlined in a practice unit released September 1. The Practice Unit covers: (1) basic concept of FTC including modified world-wide taxation, double-taxation, and foreign tax credit limitation; (2) taxpayers eligible to claim FTC, including domestic corporations; (3) what foreign taxes qualify for the FTC?; (4) Types of FTCs available; (5) Tax code Section 78 gross-up; (6) foreign tax credit vs. foreign tax deduction and making the annual election to claim FTC made on Form 1118, and (7) carryback and carryforward ...