Transition rules

Allowance of credit for taxes

Income, war profits, or excess profits tax paid or accrued

Dual capacity taxpayers

Reduction in amount of foreign taxes on foreign mineral income allowed as a credit

Look-through rules as applied to controlled foreign corporations and other entities

Allocation and apportionment of taxes

Transition rules

[Reserved]

Denial of foreign tax credit with respect to certain foreign countries

Definitions

Covered asset acquisitions and relevant foreign assets

Disqualified tax amount and aggregate basis difference carryover

Determination of basis difference

Basis difference taken into account

Successor rules

De minimis rules

Miscellaneous

Outline of regulations provisions for section 902

Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation

Treatment of deficits in post-1986 undistributed earnings and pre-1987 accumulated profits of a first- or lower-tier corporation for purposes of computing an amount of foreign taxes deemed paid under §1.902-1

Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid with respect to accumulated profits of taxable years of the foreign corporation beginning before January 1, 1987

Rules for distributions attributable to accumulated profits for taxable years in which a first-tier corporation was a less developed country corporation

Taxes in lieu of income taxes

Limitation on credit for foreign taxes

Carryback and carryover of unused foreign tax

Carryback and carryover of unused foreign tax by spouses making a joint return

Separate application of section 904 with respect to certain categories of income

Outline of regulation provisions

Special rules for capital gains and losses

Special rules for application of section 904(b) to alternative minimum tax foreign tax credit

Disregard of certain dividends and deductions under section 904(b)(4)

Outline of regulation provisions

Overall foreign loss and the overall foreign loss account

Recapture of overall foreign losses

Allocation of net operating losses and net capital losses

Recapture of foreign losses out of accumulation distributions from a foreign trust

Special rules for recapture of overall foreign losses of a domestic trust

Transitional rule for recapture of FORI and general limitation overall foreign losses incurred in taxable years beginning before January 1, 1983, from foreign source taxable income subject to the general limitation in taxable years beginning after December 31, 1982

Separate limitation loss and the separate limitation loss account

Recapture of separate limitation loss accounts

Outline of regulation provisions

Overall domestic loss and the overall domestic loss account

Recapture of overall domestic losses

Ordering rules for the allocation of net operating losses, net capital losses, U.S. source losses, and separate limitation losses, and for the recapture of separate limitation losses, overall foreign losses, and overall domestic losses

Outline of regulation provisions

Limitation on use of deconsolidation to avoid foreign tax credit limitations

Outline of regulation provisions

Certain individuals exempt from foreign tax credit limitation

When credit for taxes may be taken

Conditions of allowance of credit

Adjustments to U.S. tax liability as a result of a foreign tax redetermination

Notification of foreign tax redetermination (temporary)

Foreign tax redeterminations and currency translation rules for foreign tax redeterminations occurring in taxable years beginning prior to January 1, 1987 (temporary)

Outline of regulation provisions for section 907

Introduction (for taxable years beginning after December 31, 1982)

Reduction in taxes paid on FOGEI (for taxable years beginning after December 31, 1982)

Reduction of creditable FORI taxes (for taxable years beginning after December 31, 1982)

Definitions relating to FOGEI and FORI (for taxable years beginning after December 31, 1982)

Section 907(c)(3) items (for taxable years beginning after December 31, 1982)

FOGEI and FORI taxes (for taxable years beginning after December 31, 1982)

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

[Reserved]

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