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Foreign Tax Credit for Exempt Organizations
IRC §515
Allows tax-exempt organizations to claim a credit for foreign taxes paid on unrelated business taxable income (UBTI).
Eligibility
Available to exempt organizations subject to tax under section 511 that have foreign-sourced unrelated business income.
Frequently Asked Questions
Who is eligible for the Foreign Tax Credit for Exempt Organizations?
Available to exempt organizations subject to tax under section 511 that have foreign-sourced unrelated business income.
How does the Foreign Tax Credit for Exempt Organizations work?
Allows tax-exempt organizations to claim a credit for foreign taxes paid on unrelated business taxable income (UBTI).
What law authorizes the Foreign Tax Credit for Exempt Organizations?
The Foreign Tax Credit for Exempt Organizations is authorized under IRC §515 of the Internal Revenue Code (Title 26, United States Code).
Statutory Text — IRC §515
Source: Internal Revenue Code, Title 26, United States Code
§ 515. Taxes of foreign countries and possessions of the United States
The amount of taxes imposed by foreign countries and possessions of the United States shall be allowed as a credit against the tax of an organization subject to the tax imposed by section 511 to the extent provided in section 901; and in the case of the tax imposed by section 511, the term “taxable income” as used in section 901 shall be read as “unrelated business taxable income”.
(Aug. 16, 1954, ch. 736, 68A Stat. 176.)
Legal Sources
US Code (Official) — 26 USC §515 → Cornell Law Institute — 26 USC §515 → Search IRS.gov for IRC §515 → Treasury Regulations (26 CFR) →Discovered by: discovery_engine_v1
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