Page 180 - International Taxation IRS Training Guides

Deemed Paid Foreign Tax Credit (Cont’d)

subpart F
 TCJA retains a deemed-paid credit for

inclusions
and extends it to GILTI inclusions (IRC

960(a) and (d))

 TCJA
modifies this credit so that allowable credit based

F income
on current-year taxes attributable to subpart

than a multi-year pooling approach
rather

 TCJA also provides
rules applicable to foreign taxes

of previously taxed income
attributable to distributions

tax years of foreign corporations beginning
 Effective for

2017 and to tax years of US shareholders with or
after
within which such tax
years of foreign corporations end

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