§1.907(a)-0   Introduction (for taxable years beginning after December 31, 1982).

(a) Effective dates.

(b) Key terms.

(c) FOGEI tax limitation.

(d) Reduction of creditable FORI taxes.

(e) FOGEI and FORI.

(f) Posted prices.

(g) Transitional rules.

(h) Section 907(f) carrybacks and carryovers.

(i) Statutes covered.

§1.907(a)-1   Reduction in taxes paid on FOGEI (for taxable years beginning after December 31, 1982).

(a) Amount of reduction.

(b) Foreign taxes paid or accrued.

(1) Foreign taxes.

(2) Foreign taxes paid or accrued.

(c) Limitation level.

(1) In general.

(2) Limitation percentage of corporations.

(3) Limitation percentage of individuals.

(4) Losses.

(5) Priority.

(d) Illustrations.

(e) Effect on other provisions.

(1) Deduction denied.

(2) Reduction inapplicable.

(3) Section 78 dividend.

(f) Section 904 limitation.

§1.907(b)-1   Reduction of creditable FORI taxes (for taxable years beginning after December 31, 1982).

§1.907(c)-1   Definitions relating to FOGEI and FORI (for taxable years beginning after December 31, 1982).

(a) Scope.

(b) FOGEI.

(1) General rule.

(2) Amount.

(3) Other circumstances.

(4) Income directly related to extraction.

(5) Income not included.

(6) Fair market value.

(7) Economic interest.

(c) Carryover of foreign oil extraction losses.

(1) In general.

(2) Reduction.

(3) Foreign oil extraction loss defined.

(4) Affiliated groups.

(5) FOGEI taxes.

(6) Examples.

(d) FORI.

(1) In general.

(2) Transportation.

(3) Distribution or sale.

(4) Processing.

(5) Primary product from oil.

(6) Primary product from gas.

(7) Directly related income.

(e) Assets used in a trade or business.

(1) In general.

(2) Section 907(c) activities.

(3) Stock.

(4) Losses on sale of stock.

(5) Character of gain or loss.

(6) Allocation of amount realized.

(7) Interest.

(f) Terms and items common to FORI and FOGEI.

(1) Minerals

(2) Taxable income.

(3) Interest on working capital.

(4) Exchange gain or loss.

(5) Allocation.

(6) Facts and circumstances.

(g) Directly related income.

(1) In general.

(2) Directly related services.

(3) Leases and licenses.

(4) Related person.

(5) Gross income.

(h) Coordination with other provisions.

(1) Certain adjustments.

(2) Section 901(f).

§1.907(c)-2   Section 907(c)(3) items (for taxable years beginning after December 31, 1982).

(a) Scope.

(b) Dividend.

(1) Section 1248.

(2) Section 78 dividend.

(c) Taxes deemed paid.

(1) Voting stock test.

(2) Dividends and interest.

(3) Amounts included under section 951(a).

(d) Amount attributable to certain items.

(1) Certain dividends.

(2) Interest received from certain foreign corporations.

(3) Dividends from domestic corporation.

(4) Amounts with respect to which taxes are deemed paid under section 960(a).

(5) Section 78 dividend.

(6) Special rule.

(7) Deficits.

(8) Illustrations.

(e) Dividends, interest, and other amounts from sources within a possession.

(f) Income from partnerships, trusts, etc.

§1.907(c)-3   FOGEI and FORI taxes (for taxable years beginning after December 31, 1982).

(a) Tax characterization, allocation and apportionment.

(1) Scope.

(2) Three classes of income.

(3) More than one class in a foreign tax base.

(4) Allocation of tax within a base.

(5) Modified gross income.

(6) Allocation of tax credits.

(7) Withholding taxes.

(b) Dividends.

(1) In general.

(2) Section 78 dividend.

(c) Includable amounts under section 951(a).

(d) Partnerships.

(e) Illustrations.

§1.907(d)-1   Disregard of posted prices for purposes of chapter 1 of the Code (for taxable years beginning after December 31, 1982).

(a) In general.

(1) Scope.

(2) Initial computation requirement.

(3) Burden of proof.

(4) Related parties.

(b) Adjustments.

(c) Definitions.

(1) Foreign government.

(2) Minerals.

(3) Posted price.

(4) Other pricing arrangement.

(5) Fair market value.

§1.907(f)-1   Carryback and carryover of credits disallowed by section 907(a) (for amounts carried between taxable years that each begin after December 31, 1982).

(a) In general.

(b) Unused FOGEI.

(1) In general.

(2) Year of origin.

(c) Tax deemed paid or accrued.

(d) Excess extraction limitation.

(e) Excess general section 904 limitation.

(f) Section 907(f) priority.

(g) Cross-reference.

(h) Example.