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U.S. IRS Publishes Practice Unit on Foreign Tax Credit General Principles for Business — Orbitax Tax News & Alerts

The U.S. IRS has published a practice unit on FTC (Business) General Principles. The general overview of the practice unit is as follows:

This Practice Unit discusses the following business Foreign Tax Credit (FTC) general principles. The Unit addresses the FTC as changed by the Tax Cuts and Jobs Act of 2017 (TCJA).

  • Basic concept of FTC
    • Modified world-wide taxation
    • Double-taxation
    • Foreign tax credit limitation
  • Taxpayers eligible to claim FTC
    • Domestic corporations
  • What foreign taxes qualify for the FTC?
  • Types of FTCs available
  • Section 78 Gross-Up
  • Foreign tax credit vs. foreign tax deduction
    • Annual election to claim FTC made on Form 1118
  • Carryback and carryforward of unused credit
  • Other changes made by TCJA

Click the following link for the International Practice Units page on the IRS website.