![]() ![]() ![]() (2) The foreign tax is a tax in lieu of an income tax, as defined in § 1.903–1(b). (1) The foreign tax is a net income tax, as defined in paragraph (a)(3) of this section or A foreign levy is a foreign income tax only if. A foreign tax either is or is not a foreign income tax, in its entirety, for all persons subject to the foreign tax. ![]() Whether a foreign levy is a foreign income tax is determined independently for each separate levy. Section 901 allows a credit for the amount of income, war profits, and excess profits taxes paid during the taxable year to any foreign country, and section 903 provides that for purposes of Part III of subchapter N of the Code and sections 164(a) and 275(a), such taxes include a tax paid in lieu of a tax on income, war profits or excess profits that is otherwise generally imposed by a foreign country (collectively, for purposes of this section, a “foreign income tax”). Paragraph (h) of this section provides the applicability date for this section. Paragraph (g) of this section defines the terms used in this section, and in particular provides that the term “paid” means “paid” or “accrued,” depending on the taxpayer's method of accounting for foreign income taxes. Paragraph (f) of this section contains rules for determining by whom foreign income tax is paid. Paragraph (e) of this section provides rules for determining the amount of foreign income tax paid by a taxpayer. Paragraph (d) of this section contains rules describing what constitutes a separate levy. Paragraph (c) of this section is reserved. Paragraphs (a) and (b) of this section define a foreign income tax for purposes of section 901. (a) Definition of foreign income tax-(1) Overview and scope. § 1.901-2 Income, war profits, or excess profits tax paid or accrued. ![]()
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