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Title 26

Displaying title 26, up to date as of 9/10/2026. Title 26 was last amended 9/08/2026.
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  1. Title 26 —Internal Revenue
  2. Chapter I —Internal Revenue Service, Department of the Treasury
  3. Subchapter A —Income Tax
  4. Part 1 —Income Taxes
  5. Foreign Tax Credit   View Full Text
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Title 26Internal RevenuePart / Section
Chapter IInternal Revenue Service, Department of the Treasury1 – 899
Subchapter AIncome Tax1 – 18
Part 1Income Taxes1.0-1 – 1.9300-1
Foreign Tax Credit1.901-1 – 1.907(f)-1
§ 1.901-1Allowance of credit for foreign income taxes.
§ 1.901-2Income, war profits, or excess profits tax paid or accrued.
§ 1.901-2ADual capacity taxpayers.
§ 1.901-3Reduction in amount of foreign taxes on foreign mineral income allowed as a credit.
§ 1.901(j)-1Denial of foreign tax credit with respect to certain foreign countries.
§ 1.901(m)-1Definitions.
§ 1.901(m)-2Covered asset acquisitions and relevant foreign assets.
§ 1.901(m)-3Disqualified tax amount and aggregate basis difference carryover.
§ 1.901(m)-4Determination of basis difference.
§ 1.901(m)-5Basis difference taken into account.
§ 1.901(m)-6Successor rules.
§ 1.901(m)-7De minimis rules.
§ 1.901(m)-8Miscellaneous.
§ 1.902-0Outline of regulations provisions for section 902.
§ 1.902-1Credit for domestic corporate shareholder of a foreign corporation for foreign income taxes paid by the foreign corporation.
§ 1.902-2Treatment 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.
§ 1.902-3Credit 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.
§ 1.902-4Rules for distributions attributable to accumulated profits for taxable years in which a first-tier corporation was a less developed country corporation.
§ 1.903-1Taxes in lieu of income taxes.
§ 1.904-1Limitation on credit for foreign income taxes.
§ 1.904-2Carryback and carryover of unused foreign tax.
§ 1.904-3Carryback and carryover of unused foreign tax by spouses making a joint return.
§ 1.904-4Separate application of section 904 with respect to certain categories of income.
§ 1.904-5Look-through rules as applied to controlled foreign corporations and other entities.
§ 1.904-6Allocation and apportionment of foreign income taxes.
§ 1.904-7Transition rules.
§ 1.904(b)-0Outline of regulation provisions.
§ 1.904(b)-1Special rules for capital gains and losses.
§ 1.904(b)-2Special rules for application of section 904(b) to alternative minimum tax foreign tax credit.
§ 1.904(b)-3Disregard of certain dividends and deductions under section 904(b)(4).
§ 1.904(f)-0Outline of regulation provisions.
§ 1.904(f)-1Overall foreign loss and the overall foreign loss account.
§ 1.904(f)-2Recapture of overall foreign losses.
§ 1.904(f)-3Allocation of net operating losses and net capital losses.
§ 1.904(f)-4Recapture of foreign losses out of accumulation distributions from a foreign trust.
§ 1.904(f)-5Special rules for recapture of overall foreign losses of a domestic trust.
§ 1.904(f)-6Transitional 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.
§ 1.904(f)-7Separate limitation loss and the separate limitation loss account.
§ 1.904(f)-8Recapture of separate limitation loss accounts.
§§ 1.904(f)-9-1.904(f)-11 [Reserved]
§ 1.904(f)-12Transition rules.
§ 1.904(g)-0Outline of regulation provisions.
§ 1.904(g)-1Overall domestic loss and the overall domestic loss account.
§ 1.904(g)-2Recapture of overall domestic losses.
§ 1.904(g)-3Ordering 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.
§ 1.904(i)-0Outline of regulation provisions.
§ 1.904(i)-1Limitation on use of deconsolidation to avoid foreign tax credit limitations.
§ 1.904(j)-0Outline of regulation provisions.
§ 1.904(j)-1Certain individuals exempt from foreign tax credit limitation.
§ 1.905-1When credit for foreign income taxes may be taken.
§ 1.905-2Conditions of allowance of credit.
§ 1.905-3Adjustments to U.S. tax liability and to current earnings and profits as a result of a foreign tax redetermination.
§ 1.905-4Notification of foreign tax redetermination.
§ 1.905-5Foreign tax redeterminations of foreign corporations that relate to taxable years of the foreign corporation beginning before January 1, 2018.
§ 1.907-0Outline of regulation provisions for section 907.
§ 1.907(a)-0Introduction (for taxable years beginning after December 31, 1982).
§ 1.907(a)-1Reduction in taxes paid on FOGEI (for taxable years beginning after December 31, 1982).
§ 1.907(b)-1Reduction of creditable FORI taxes (for taxable years beginning after December 31, 1982).
§ 1.907(c)-1Definitions relating to FOGEI and FORI (for taxable years beginning after December 31, 1982).
§ 1.907(c)-2Section 907(c)(3) items (for taxable years beginning after December 31, 1982).
§ 1.907(c)-3FOGEI and FORI taxes (for taxable years beginning after December 31, 1982).
§ 1.907(d)-1Disregard of posted prices for purposes of chapter 1 of the Code (for taxable years beginning after December 31, 1982).
§ 1.907(e)-1 [Reserved]
§ 1.907(f)-1Carryback and carryover of credits disallowed by section 907(a) (for amounts carried between taxable years that each begin after December 31, 1982).
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