Prop. Treas. Reg. § 1.901-1 Allowance of credit for foreign income taxes.

Proposed 2026-08-03 · REG-115145-25 · 91 FR 48794 · Interprets § 901 · Would amend § 1.901-1

Par. 6. Section 1.901-1 is amended by revising paragraph (b) to read as follows:

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(b) Limitations. Certain Code sections, including sections 245A(d) and (e)(3), 814, 901(e) through (m), 904, 906 through 909, 911, 960(d)(4), 965(g), 999, and 6038, reduce, defer, or otherwise limit the credit against the tax imposed by chapter 1 of the Code for certain amounts of foreign income taxes.

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