LB&I Process Unit - IRS tax forms

If a rate differential exists, the rules of IRC 904(b)(2)(B) require three adjustments to the IRC 904(a) fractional limitation ( two apply to the numerator and one applies to the denominator): IRC 904(b)(2)(B)(i) limits the portion of capital gains that enter the numerator (foreign- source taxable income) to the taxpayer ’s

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