Page 181 - International Taxation IRS Training Guides

Other Foreign Tax Credit Changes

 TCJA creates a separate foreign tax credit limitation

basket
for foreign branch income (IRC 904(d)(1)(B))

and GILTI
income (IRC 904(d)(1)(A))

 TCJA
repealed the fair market value method of valuing

assets for purposes
of interest expense apportionment
under
IRC 864(e)(2); now, tax basis must be used in all

cases

eligible for IRC 245A DRD are not treated as
 Dividends

but under IRC 904(b)(4), expenses
exempt,

are added back in computing
apportioned to dividends
the IRC 904 FTC limitation

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