The U.S. IRS has released an international practice unit on Qualified Dividends and Capital Gains Rate Differential Adjustments for individual foreign tax credits. The general overview of the practice unit includes the following:
The United States (U.S.) taxes its individual residents and citizens on their worldwide income. To prevent double taxation, U.S. taxpayers are allowed a credit for foreign income taxes "paid or accrued" on income that is taxed by both the U.S. and a foreign country…