IRS Practice Unit: Overall Foreign, Domestic Losses Limiting Foreign Tax Credit (IRC §904)

Overview of the overall foreign loss (OFL), separate limitation loss (SLL), and overall domestic loss (ODL) rules outlined in an IRS Large Business and International Concept Unit practice unit released September 17. The rules cover the determination of a taxpayer’s foreign tax credit. The practice unit covers when a net loss offsets net income of a different source or a different category of foreign taxable income (FTI), loss recapture rules are triggered. [IRS Practice Unit Overall Foreign and Domestic Losses (last updated Sept. 1, 2020)]

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