Foreign Tax Credit (FTC)
A dollar-for-dollar credit on the US tax return for income taxes paid to a foreign country, designed to prevent double taxation.
Detailed Explanation
The Foreign Tax Credit under IRC Section 901 provides a dollar-for-dollar reduction of US tax for foreign income taxes paid or accrued. It is the primary mechanism for preventing double taxation when a US person earns income from a foreign source. The credit is computed on Form 1116 (individuals) or Form 1118 (corporations) and applied against US tax liability. Critical limitation: the FTC cannot exceed the US tax attributable to foreign-source income (the "Section 904 limit"). The limit is calculated by taking foreign-source taxable income divided by total taxable income, multiplied by US tax. Foreign income falls into separate "baskets" that are computed independently (each with its own limit): passive category (interest, dividends, capital gains), general category (wages, business income), GILTI category, foreign branch category, and a few specialized buckets. Excess credits in a given year and basket can be carried back 1 year or forward 10 years (carrybacks must be filed within 10 years of the original return). For high-tax-country expats, FTC is usually more beneficial than the FEIE: foreign tax paid on wages often equals or exceeds the entire US tax liability, eliminating it without giving up earned income for IRA contributions. For low-tax-country expats, FEIE may be better. A combined approach (FEIE up to $132,900 for 2026, then FTC on the excess) is also available. Election: FTC can be deducted instead of credited (rarely better, since deduction value is at marginal rate vs full dollar credit).
Key Points
- Dollar-for-dollar credit on Form 1116 (individuals) or Form 1118 (corporations).
- Limited under §904 to the US tax on foreign-source income; computed separately by category (passive, general, GILTI, etc.).
- Excess can carry back 1 year or forward 10 years.
- Generally better than FEIE for high-tax-country expats (preserves earned income for IRA, refundable CTC, etc.).
- Can be combined with FEIE: claim FEIE up to $132,900 for 2026, then FTC on income above that.
Related TS CPA Service
US tax returns and foreign asset reporting for Americans abroad, foreign nationals in the US, and anyone holding offshore accounts or entities.
Learn about International TaxationRelated Terms
Foreign Earned Income Exclusion (FEIE)
A tax provision allowing qualifying US citizens and residents living abroad to exclude a portion of foreign-earned wages and self-employment income from US taxation.
GILTI (Global Intangible Low-Taxed Income)
A US tax on foreign income earned by Controlled Foreign Corporations in excess of a deemed routine return on tangible assets.
Subpart F Income
Certain types of foreign income earned by Controlled Foreign Corporations that are taxed currently to US shareholders, regardless of distribution.
Passive Foreign Investment Company (PFIC)
A foreign corporation that earns mostly passive income or holds mostly passive assets, subjecting US shareholders to a punitive tax regime under IRC Sections 1291 to 1298. Most foreign mutual funds and ETFs are PFICs.
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