26 C.F.R. § 1.904(i)-0. - § 1.904(i)-0 Outline of Regulation Provisions.
Current as of January 1, 1970
Section 1.904(g)-3 - § 1.904(g)-3 Ordering Rules for the Allocation of Net Operating Losses, Net Capital Losses, U.s. Source Losses, and Separate Limitation Losses, and for the Recapture of Separate Limitation Losses, Overall Foreign Losses, and Overall Domestic Losses.Section 1.904(i)-1 - § 1.904(i)-1 Limitation on Use of Deconsolidation to Avoid Foreign Tax Credit Limitations.
§ 1.904(i)-0 Outline of regulation provisions.
This 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.
(2) Allocation.
(b) Definitions and special rules.
(1) Affiliate.
(i) Generally.
(ii) Rules for consolidated groups.
(iii) Exception for newly acquired affiliates.
(2) Includible corporation.
(c) Taxable years.
(d) Consistent treatment of foreign taxes paid.
(e) Effective date.
[T.D. 9371, 72 FR 72603, Dec. 21, 2007]
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