Treasury Regulations · 26 CFR
§ 1.907(a)-1. Reduction in taxes paid on FOGEI (for taxable years beginning after December 31, 1982).
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Regulation under 26 U.S.C. § 907(a)
Cite as 26 CFR § 1.907(a)-1
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- March 15, 1991 by T.D. 8338
- Issued under
- 26 U.S.C. § 907(a)
- Length
- 881 words · about 4 min to read
- Defines
- 1 term
- Cross-references
- cites 11 Code sections and 2 regulations; cited by 5
M, a U.S. corporation, uses the accrual method of accounting and the calendar year as its taxable year. For 1984, M has $20,000 of FOGEI, derived from operations in foreign countries X and Y, and has accrued $11,500 of foreign taxes with respect to FOGEI. The highest tax rate specified in section 11(b) for M's 1984 taxable year is 46 percent. Pursuant to section 907(a), M's FOGEI taxes limitation level for 1984 is $9,200 (46% × $20,000). The foreign taxes in excess of this limitation level ($2,300) may be carried back or forward. See section 907(f) and § 1.907(f)-1 and section 907(e) and § 1.907(e)-1.
The facts are the same as in Example 1 except that M is a partnership owned equally by U.S. citizens A and B who each file as unmarried individuals and do not itemize deductions. Pursuant to section 905(a), A and B have elected to credit foreign taxes in the year accrued. The total amount of foreign taxes accrued by A and B with respect to their distributive shares of M's FOGEI is $11,500 ($5,750 accrued by A and $5,750 accrued by B). A and B have no other FOGEI. A's only taxable income for 1984 is his 50% distributive share ($10,000) of M's FOGEI and A has a preliminary U.S. tax liability of $1,079. B has $112,130 of taxable income for 1984 (including his 50% distributive share ($10,000) of M's FOGEI) and has a preliminary U.S. tax liability of $44,000. Pursuant to section 907(a), A's FOGEI taxes limitation level for 1984 is $1,079 (($1,079/$10,000) × $10,000) and B's FOGEI taxes limitation level for 1984 is $3,924 (($44,000/$112,130) × $10,000).
[T.D. 8338, 56 FR 11066, Mar. 15, 1991]
Terms defined here
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Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
- § 907 Special rules in case of foreign oil and gas income
- § 901 Taxes of foreign countries and of possessions of United States
- § 903 Credit for taxes in lieu of income, etc., taxes
- § 902 Repealed
- § 904 Limitation on credit
- § 11 Tax imposed
- § 908 Reduction of credit for participation in or cooperation with an international boycott
- § 905 Applicable rules
- § 164 Taxes
- § 275 Certain taxes
- § 78 Gross up for deemed paid foreign tax credit
Regulations it cites
- § 1.907(c)-1 Definitions relating to FOGEI and FORI (for taxable years beginning after December 31, 1982).
- § 1.907(f)-1 Carryback and carryover of credits disallowed by section 907(a) (for amounts carried between taxable years that each begin after December 31, 1982).
Cited by 5 other regulations
- § 1.78-1 Gross up for deemed paid foreign tax credit.
- § 1.907-0 Outline of regulation provisions for section 907.
- § 1.907(a)-0 Introduction (for taxable years beginning after December 31, 1982).
- § 1.907(c)-1 Definitions relating to FOGEI and FORI (for taxable years beginning after December 31, 1982).
- § 1.907(f)-1 Carryback and carryover of credits disallowed by section 907(a) (for amounts carried between taxable years that each begin after December 31, 1982).
Amendment history
From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.
- Issued by T.D. 8338 (56 FR 11066)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Foreign tax credit
Nearby sections
- § 1.905-4 Notification of foreign tax redetermination.
- § 1.905-5 Foreign tax redeterminations of foreign corporations that relate to taxable years of the foreign corporation beginning before January 1, 2018.
- § 1.907-0 Outline of regulation provisions for section 907.
- § 1.907(a)-0 Introduction (for taxable years beginning after December 31, 1982).
- § 1.907(a)-1 Reduction in taxes paid on FOGEI (for taxable years beginning after December 31, 1982).
- § 1.907(b)-1 Reduction of creditable FORI taxes (for taxable years beginning after December 31, 1982).
- § 1.907(c)-1 Definitions relating to FOGEI and FORI (for taxable years beginning after December 31, 1982).
- § 1.907(c)-2 Section 907(c)(3) items (for taxable years beginning after December 31, 1982).
- § 1.907(c)-3 FOGEI and FORI taxes (for taxable years beginning after December 31, 1982).