U.S. IRS Releases Practice Unit on Flow-Through Entities Effects on FTC

The U.S. IRS has released an international practice unit on Flow-Through Entities Effects on Foreign Tax Credit (FTC). The general overview of the practice unit is provided as follows:

Flow-through entities (FTEs) affect an individual’s Foreign Tax Credit (FTC) by impacting foreign source gross income, foreign source taxable income, worldwide gross income, worldwide taxable income and foreign taxes available for credit.

Each U.S. partner of a partnership must report the partner’s distribu…