Treasury Regulations (26 C.F.R.)
26 CFR § 1.901(j)-1
Denial of foreign tax credit with respect to certain foreign countries.
Official textecfr.govlast amended
# (a) Sourcing rule for certain payments and inclusions.
Any income paid or accrued through one or more entities is treated as income from sources within a country described in section 901(j)(2) if the income was, without regard to such entities, from sources within that country.
# (b) Applicability date.
This section applies to taxable years that end on or after December 4, 2018.
[T.D. 9882, 84 FR 69075, Dec. 17, 2019]
Source: view the official text
In this part (40 sections)
- 1.892-7T · Relationship to other Internal Revenue Code sections…
- 1.893-1 · Compensation of employees of foreign governments or…
- 1.894-1 · Income affected by treaty.
- 1.895-1 · Income derived by a foreign central bank of issue, or by Bank…
- 1.897-1 · Taxation of foreign investment in United States real property…
- 1.897-2 · United States real property holding corporations.
- 1.897-3 · Election by foreign corporation to be treated as a domestic…
- 1.897-4AT · Table of contents (temporary).
- 1.897-5 · Corporate distributions.
- 1.897-5T · Corporate distributions (temporary).
- 1.897-6T · Nonrecognition exchanges applicable to corporations, their…
- 1.897-7 · Treatment of certain partnership interests, trusts and…
- 1.897-7T · Treatment of certain partnership interests as entirely U.S.…
- 1.897-8T · Status as a U.S. real property holding corporation as a…
- 1.897-9T · Treatment of certain interest in publicly traded…
- 1.897(l)-1 · Exception for interests held by foreign pension funds.
- 1.901-1 · Allowance of credit for foreign income taxes.
- 1.901-2 · Income, war profits, or excess profits tax paid or accrued.
- 1.901-2A · Dual capacity taxpayers.
- 1.901-3 · Reduction in amount of foreign taxes on foreign mineral…
- 1.901(j)-1 · Denial of foreign tax credit with respect to certain…
- 1.901(m)-1 · Definitions.
- 1.901(m)-2 · Covered asset acquisitions and relevant foreign assets.
- 1.901(m)-3 · Disqualified tax amount and aggregate basis difference…
- 1.901(m)-4 · Determination of basis difference.
- 1.901(m)-5 · Basis difference taken into account.
- 1.901(m)-6 · Successor rules.
- 1.901(m)-7 · De minimis rules.
- 1.901(m)-8 · Miscellaneous.
- 1.902-0 · Outline of regulations provisions for section 902.
- 1.902-1 · Credit for domestic corporate shareholder of a foreign…
- 1.902-2 · Treatment of deficits in post-1986 undistributed earnings and…
- 1.902-3 · Credit for domestic corporate shareholder of a foreign…
- 1.902-4 · Rules for distributions attributable to accumulated profits…
- 1.903-1 · Taxes in lieu of income taxes.
- 1.904-1 · Limitation on credit for foreign income taxes.
- 1.904-2 · Carryback and carryover of unused foreign tax.
- 1.904-3 · Carryback and carryover of unused foreign tax by spouses…
- 1.904-4 · Separate application of section 904 with respect to certain…
- 1.904-5 · Look-through rules as applied to controlled foreign…