Rev. Rul. 83-88

1983-1 C.B. 130.

                       Internal Revenue Service
                                 Revenue Ruling

                               FOREIGN TAX CREDIT

                            Published: June 20, 1983

SECTION 901. - -TAXES OF FOREIGN COUNTRIES AND OF POSSESSIONS OF UNITED STATES, 26 CFR 4.901-2: Income, was profits, or excess profits taxes paid or accrued

(Also Section 903; 4.903-1.)

  Foreign tax credit.  The enumerated taxes imposed by various foreign countries or provinces have been determined to be creditable income taxes for purposes of the foreign tax credit.  Rev. Rul. 82-119 supplemented.

  The Internal Revenue Service has determined that the following charges are creditable income taxes for purposes of sections 901 and 903 of the Internal Revenue Code and sections 4.901-2 and 4.903-1 of the Temporary Income Tax Regulations, T.D. 7739, 1981-1 C.B. 396.

  This ruling does not bear upon the issue of whether a listed tax has been paid or accrued.  Nor does the ruling deal with contractual modifications of a listed tax.  Finally, certain listed taxes are held creditable for specified taxpayers.  These limitations do not reflect any determination with regard to taxpayers not specified.

AUSTRALIA
  1. Section 17, Australian Income Tax Assessment Act, in effect on April 15, 1980.
  2. Section 128T, Australian Income Tax Assessment Act, in effect on April 15, 1980.
CANADA
  1. Income Tax Act, R.S.C. 1980-81, in effect on February 26, 1981  (Corporation Tax).
  2. Alberta Corporate Income Tax Act, R.S.A. 1980, c. A-17, in effect on February 26, 1981.
  3. Ontario Corporations Tax Act, R.S.O. 1972, c. 143, in effect on February 12, 1981.
  4. Quebec Taxation Act, R.S.Q., c. I-3, in effect on April 8, 1980  (Corporation Tax).
IVORY COAST
  1. Art. 1, General Tax Code of the Republic of Ivory Coast, in effect on November 7, 1980, only as applied to nonpetroleum operations.
  2. Article 2, Law No. 62-61 of February 16, 1962 (National Contribution Tax), in effect on November 7, 1980 which is incorporated in Article 27, General Tax Code of the Republic of Ivory Coast.
  3. Art. 934, General Tax Code of the Republic of Ivory Coast, in effect on November 7, 1980.
PERU
  1. Art. 62 (Art. 21 Third Category), Legislative Decree No. 200, as modified by Law No. 23337, in effect on January 1, 1982.
  2. Art. 63(b), Legislative Decree No. 200, as modified by Law 23337, in effect on January 1, 1982.
EFFECT ON OTHER REV. RULS.

  Rev. Rul. 82-119, 1982-1 C.B. 105, supplemented.

Rev. Rul. 83-88, 1983-1 C.B. 130.