The U.S. IRS has released an international practice unit, Overall Foreign and Domestic Losses. The general overview of the practice unit is provided as follows:
The United States generally taxes U.S. persons on their worldwide income, including their Foreign Taxable Income (FTI). The Foreign Tax Credit (FTC) generally prevents U.S. taxpayers from being taxed twice on their FTI - once by the foreign country where the income is earned, and a second time by the United States. The FTC generally…