tested foreign income taxes

(3) Tested foreign income taxes For purposes of paragraph (1), the term “tested foreign income taxes” means, with respect to any domestic corporation which is a United States shareholder of a controlled foreign corporation, the foreign income taxes paid or accrued by such foreign corporation which are properly attributable to the tested income of such foreign corporation taken into account by such domestic corporation under section 951A.

Source

26 USC § 960(d)(3)

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Scoping language

None identified, default scope is assumed to be the parent (subpart F) of this section.

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