The U.S. IRS has published an updated international practice unit on Flow-Through Entities Effects on Foreign Tax Credit (FTC). The general overview of the practice unit includes the following:
NOTE: This Practice Unit is updated to reflect the recent finalized Treas. Reg. 1.861-9.
Flow-through entities (FTEs) affect an individual's Foreign Tax Credit (FTC) by impacting foreign source gross income, foreign source taxable income, worldwide gross income, worldwide taxable income and foreign …