26 CFR § 1.901(j)-1

26 CFR · Internal Revenue

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

26 CFR § 1.901(j)-1

TitleTitle 26: Internal Revenue PartPart 1: Income Taxes

SourceeCFR (current through Mar 20, 2026)

This text of 26 C.F.R. § 1.901(j)-1 (Denial of foreign tax credit with respect to certain foreign countries.) is published on Counsel Stack Legal Research, covering United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

26 C.F.R. § 1.901(j)-1 (2026).

Text

§ 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]

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§ 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]