General Income:
It includes all income other than passive income. It includes most of the foreign source active business profits of domestic corporations and their foreign subsidiaries.
Passive...
After computation of creditable foreign income taxes, next step is to compute foreign tax credit limitation.
Example:
USAco has U.S source income = 200
Foreign source taxable...
The United States restricts the credit to foreign income taxes that duplicate the U.S income tax against which the credit is taken.
Under code section 901, a foreign levy must...