Current through September 30, 2024
Section 1.904(i)-0 - Outline of regulation provisionsThis section lists the headings for § 1.904(i)-1 .
§ 1.904(i)-1 Limitation on use of deconsolidation to avoid foreign tax credit limitations. (a) General rule. (1) Determination of taxable income.(b) Definitions and special rules. (1) Affiliate. (ii) Rules for consolidated groups.(iii) Exception for newly acquired affiliates.(2) Includible corporation.(d) Consistent treatment of foreign taxes paid.T.D. 9371, 72 FR 72603, Dec. 21, 2007