WebOct 1, 2024 · Sec. 960 (b) (1) applies to distributions by a CFC to its corporate U.S. shareholder and broadly provides that foreign income taxes properly attributable to Sec. … WebIRC Section 960 (b) treats a corporate US shareholder as paying any foreign income taxes (e.g., foreign withholding taxes) that are imposed on previously taxed E&P ( PTEP) and received by an upper-tier CFC from a lower-tier CFC when the PTEP is ultimately received by the US shareholder.
26 CFR § 1.960-3 - Foreign income taxes deemed paid …
WebAs a result, taxpayers generally could not claim a credit for those taxes under IRC Section 960. The proposed revisions to Treas. Reg. Section 1.367(b)-7 would apply to a foreign corporation's tax years ending on or after November 2, 2024, which was the date the proposed regulations were filed with the Federal Register. Web§960. Deemed paid credit for subpart F inclusions (a) In general. For purposes of subpart A of this part, if there is included in the gross income of a domestic corporation any item of … thepinpeople.com
LB&I Concept Unit - IRS
WebNov 2, 2024 · For purposes of applying section 959 in any taxable year beginning with the taxable year described in subsection (a), with respect to any United States shareholder of a deferred foreign income corporation, an amount equal to such shareholder’s reduction under paragraph (1) which is allocated to such deferred foreign income corporation under this … Webthe foreign income taxes deemed paid by the taxpayer with respect to such income under section 902 1 or 960, exceeds the highest rate of tax specified in section 1 or 11 (whichever applies) multiplied by the amount of such income (determined with regard to section 78). WebSection 960 (a) provides that U.S. corporate shareholders that include “any item of income under Section 951 (a)1)” with respect to any CFC shall be deemed to have paid “so much of such foreign corporation’s foreign taxes as are properly attributable to such item of income.” the pinon project