Limitation On Use Of Deconsolidation To Avoid
Foreign Tax Credit Limitations

[4830-01-u] DEPARTMENT OF THE TREASURY Internal Revenue Service 26 CFR Part 1 [TD 8627] RIN 1545-AN87

TITLE: Limitation On Use Of Deconsolidation To Avoid Foreign Tax Credit Limitations

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Final regulations.

SUMMARY: This document contains final regulations relating to certain limitations on the amount of the foreign tax credit under section 904(i). The final regulations will affect the sourcing and foreign tax credit separate limitation character of income for purposes of the calculation of the foreign tax credit by certain related domestic corporations. The final regulations are necessary to prevent avoidance of the foreign tax credit limitations.

DATES: These regulations are effective January 1, 1994. For dates of applicability, see 1.904(i)-1(e) of these regulations.

FOR FURTHER INFORMATION CONTACT: Kenneth D. Allison, 202-622-3860 (not a toll-free number).

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