Foreign Tax Credit Limitation: Map
•What foreign income tax has been paid by taxpayer or
CFC in which it is a shareholder?
•What income does the foreign tax relate to? (Reg.
§1.904-6)
•What is the source, character and FTC limitation
category of that income?
–If it is long-term capital gain, apply rate differential
under Section 904(b).
•What expenses are allocable to that category of income?
