Election to use simplified section 904 limitation
(A) In general
(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.
(A)(i)#
subparagraph (B) of paragraph (1) shall not apply, and
(A)(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.
(A)(ii)(I)#
(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.
(B)(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.
(B)(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.