§ 1.901(j)-1  Denial of foreign tax credit with respect to certain foreign countries.

§ 1.901(j)-1(a) Sourcing rule for certain payments and inclusions. Any income paid or accrued through one or more entities is treated as income from sources within a country described in section 901(j)(2) if the income was, without regard to such entities, from sources within that country.

§ 1.901(j)-1(b) Applicability date. This section applies to taxable years that end on or after December 4, 2018.