Page 182 - International Taxation IRS Training Guides

Other Foreign Tax Credit

Changes (Cont’d)

also allows taxpayers to elect to recapture overall
 TCJA

domestic loss
accounts more quickly and
recharacterize US
source income as foreign source

income (IRC 904(g)(5))

 TCJA
modifies the sourcing of income from sales of
taxpayer-produced inventory to be based solely on

place of production (IRC
863(b))

beginning after Dec. 31,
 Effective for taxable years
2017

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