Foreign Tax Credit Allocation and Disallowance (IRC §§ 898©, 960(d)(4))

Current understanding

To be populated as evidence accumulates.

2026-09-11 — Allocation and Apportionment of Deductions to Foreign Source Section 951A Category Income and Deduction Eligible Income: cross-connection with section-951a-fddei-deduction-allocation: Both address how deductions and taxes are allocated against foreign-source income categories in computing foreign tax credit limitations. (novelty: 2)
2026-08-03 — Section 898© Transition Rule for Allocating Foreign Taxes and Section 960(d)(4) Foreign Tax Credit Disallowance: Proposed Treasury/IRS regulations establish a transition rule under IRC §898© for allocating foreign taxes of foreign corporations following repeal of the one-month deferral election, and implement §960(d)(4) to disallow foreign tax credits on certain distributions of previously taxed earnings and profits. (novelty: 2)