Page 26 - International Taxation IRS Training Guides

Intro to Outbound:
Foreign Tax Credit

USP USP

Dividend,
100% 20% e.g., $8 + $2 gross-up

under §78

Foreign

Branch CFC

• $100 active business income • $100 active business income
• $20 Foreign tax • $20 Foreign tax
• $80 Earnings and Profits

24