Overall FTC limitation
Overall FTC limitation
A limitation on the FTC equal to foreign source income times US tax on worldwide income divided by worldwide income.
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An individual with $300 or less of creditable foreign taxes ($600 if married filing jointly) is exempt from the overall FTC limitation, provided that person has no foreign source income other than qualified passive income [IRC section 904(j)].
Although Congress has rejected the enactment of one overall FTC limitation, it has generally restricted the separate FTC limitations to classes of income that were "movable.
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