IRC 960: The Deemed-Paid Foreign Tax Credit
September 29, 2026
IRC 960 explained: how a U.S. corporation that is a shareholder of a controlled foreign corporation claims credit for the foreign taxes its subsidiary paid on subpart F income and net CFC tested income (formerly GILTI), the 90 percent limit on those credits from 2026, previously taxed income distributions, and why individuals need a section 962 election.
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