§1.904(i)-1   Limitation on use of deconsolidation to avoid foreign tax credit limitations.

(a) General rule.

(1) Determination of taxable income.

(2) Allocation.

(b) Definitions and special rules.

(1) Affiliate.

(i) Generally.

(ii) Rules for consolidated groups.

(iii) Exception for newly acquired affiliates.

(2) Includible corporation.

(c) Taxable years.

(d) Consistent treatment of foreign taxes paid.

(e) Effective date.