Alternative minimum tax foreign tax credit
2 rules0 of 3 subsections
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For purposes of this part—
(1) In general
The alternative minimum tax foreign tax credit for any taxable year shall be the credit which would be determined under section 27 for such taxable year if—
(A) the pre-credit tentative minimum tax were the tax against which such credit was taken for purposes of section 904 for the taxable year and all prior taxable years beginning after December 31, 1986 ,
(B) section 904 were applied on the basis of alternative minimum taxable income instead of taxable income, and
(C) the determination of whether any income is high-taxed income for purposes of section 904(d)(2) were made on the basis of the applicable rate specified in section 55(b)(1) in lieu of the highest rate of tax specified in section 1.
the pre-credit tentative minimum tax were the tax against which such credit was taken for purposes of section 904 for the taxable year and all prior taxable years beginning after December 31, 1986 ,
section 904 were applied on the basis of alternative minimum taxable income instead of taxable income, and
the determination of whether any income is high-taxed income for purposes of section 904(d)(2) were made on the basis of the applicable rate specified in section 55(b)(1) in lieu of the highest rate of tax specified in section 1.
For purposes of this subsection, the term “pre-credit tentative minimum tax” means the amount determined under the first sentence of section 55(b)(1)(A).
(A) In general In determining the alternative minimum tax foreign tax credit for any taxable year to which an election under this paragraph applies— (i) subparagraph (B) of paragraph (1) shall not apply, and (ii) the limitation of section 904 shall be based on the proportion which— (I) the taxpayer’s taxable income (as determined for purposes of the regular tax) from sources without the United States (but not in excess of the taxpayer’s entire alternative minimum taxable income), bears to (II) the taxpayer’s entire alternative minimum taxable income for the taxable year.
(B) Election (i) In general An election under this paragraph may be made only for the taxpayer’s first taxable year which begins after December 31, 1997 , and for which the taxpayer claims an alternative minimum tax foreign tax credit. (ii) Election revocable only with consent An election under this paragraph, once made, shall apply to the taxable year for which made and all subsequent taxable years unless revoked with the consent of the Secretary.
In determining the alternative minimum tax foreign tax credit for any taxable year to which an election under this paragraph applies—
(i) subparagraph (B) of paragraph (1) shall not apply, and
(ii) the limitation of section 904 shall be based on the proportion which— (I) the taxpayer’s taxable income (as determined for purposes of the regular tax) from sources without the United States (but not in excess of the taxpayer’s entire alternative minimum taxable income), bears to (II) the taxpayer’s entire alternative minimum taxable income for the taxable year.
subparagraph (B) of paragraph (1) shall not apply, and
the limitation of section 904 shall be based on the proportion which—
(I) the taxpayer’s taxable income (as determined for purposes of the regular tax) from sources without the United States (but not in excess of the taxpayer’s entire alternative minimum taxable income), bears to
(II) the taxpayer’s entire alternative minimum taxable income for the taxable year.
the taxpayer’s taxable income (as determined for purposes of the regular tax) from sources without the United States (but not in excess of the taxpayer’s entire alternative minimum taxable income), bears to
the taxpayer’s entire alternative minimum taxable income for the taxable year.
(i) In general An election under this paragraph may be made only for the taxpayer’s first taxable year which begins after December 31, 1997 , and for which the taxpayer claims an alternative minimum tax foreign tax credit.
(ii) Election revocable only with consent An election under this paragraph, once made, shall apply to the taxable year for which made and all subsequent taxable years unless revoked with the consent of the Secretary.
An election under this paragraph may be made only for the taxpayer’s first taxable year which begins after December 31, 1997 , and for which the taxpayer claims an alternative minimum tax foreign tax credit.
An election under this paragraph, once made, shall apply to the taxable year for which made and all subsequent taxable years unless revoked with the consent of the Secretary.