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26 CFR 1.901(j)-1

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

United States · 26 CFR — Internal Revenue · Status: effective

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26 CFR 1.901(j)-1, § 1.901(j)-1 Denial of foreign tax credit with respect to certain foreign countries, United States, version 1 as recorded 2026-07-09, yourstate.us, https://yourstate.us/provision/111147
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(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.

Legislative history

This is a federal regulation, adopted through agency rulemaking under the Administrative Procedure Act — not enacted by a recorded vote of Congress.