26 CFR 1.901 - Denial of foreign tax credit with respect to certain foreign countries.

Regulations last checked for updates: Dec 17, 2025

Title 26 - Internal Revenue last revised: Sep 17, 2030

View all text of Part 1 [§ 1.851-1 - § 1.907(f)-1]

§ 1.901(j)-1 - Denial of foreign tax credit with respect to certain foreign countries.

(a) Sourcing rule for certain payments and inclusions. Any income paid or accrued through one or more entities is treated as income from sources within a country described in section 901(j)(2) if the income was, without regard to such entities, from sources within that country.

(b) Applicability date. This section applies to taxable years that end on or after December 4, 2018.

[T.D. 9882, 84 FR 69075, Dec. 17, 2019]

authority: 26 U.S.C. 7805,unless

source: T.D. 6500, 25 FR 11910, Nov. 26, 1960; 25 FR 14021, Dec. 31, 1960, unless otherwise noted.

cite as: 26 CFR 1.901