Regulations last checked for updates: Nov 22, 2024

Title 26 - Internal Revenue last revised: Nov 20, 2024
§ 1.642(a)(2)-1 - Foreign taxes.

An estate or trust is allowed the credit against tax for taxes imposed by foreign countries and possessions of the United States to the extent allowed by section 901 only for so much of those taxes as are not properly allocable under that section to the beneficiaries. See section 901(b)(4). For purposes of section 901(b)(4), the term beneficiaries includes charitable beneficiaries.

authority: Section 1.642(c)-6 also issued under 26 U.S.C. 642(c)(5)
source: T.D. 6500, 25 FR 11814, Nov. 26, 1960; 25 FR 14021, Dec. 31, 1960, unless otherwise noted.
cite as: 26 CFR 1.642