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

Proposed regulation, not in force. REG-115145-25, 91 FR 48794, published 2026-08-03 <https://www.federalregister.gov/documents/2026/08/03/2026-15614/section-898c-transition-rule-for-allocating-foreign-taxes-and-section-960d4-foreign-tax-credit>. Interprets 26 U.S.C. § 901.

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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