On 1 March 2016, the U.S. IRS published Rev. Rul. 2016-8, which amends Rev. Rul. 2005-3 to remove Cuba from the foreign tax credit (FTC) black list. The black list concerns section 901(j), which includes that a FTC will not be available for taxes paid or accrued to any listed country. The list also concerns section 952(a)(5), which provides that subpart F income includes income derived by a controlled foreign corporation from any foreign country during any period during which section 901(j) a…