Page 179 - International Taxation IRS Training Guides

Deemed
Paid Foreign Tax Credit

 Before TCJA,
a 10% corporate US shareholder of a

foreign corporation was deemed to have paid a portion

the foreign corporation’s foreign income tax under
of

902 when it received a dividend from that foreign
IRC

corporation

are now eligible for a 100%
 Because such dividends
TCJA repeals this deemed paid foreign tax credit
DRD,

 Effective for
tax years of foreign corporations beginning
after
2017 and to tax years of US shareholders with or

years of foreign corporations end
within which such tax

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