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October 20, 2004
JS-2045 Iraq Removed from List of Countries Subject to
Special Foreign Tax Credit Restrictions Today the Treasury Department issued Revenue Ruling 2004-103 to reflect the decision of the Department of State to remove Iraq from the list of countries subject to the special foreign tax credit and other restrictions of Internal Revenue Code section 901(j) and related provisions.
U.S. tax rules generally allow taxpayers a credit against U.S. income tax for taxes paid to a foreign country. Special rules in sections 901(j) and 952(a)(5) generally deny foreign tax credits and impose other restrictions if income is attributable to countries with which the United States does not conduct diplomatic relations or which have been identified as sponsors of international terrorism. These restrictions cease to apply with respect to a particular country when the Secretary of State certifies to the Secretary of the Treasury that the country no longer meets these criteria. A list of countries described in section 901(j)(2)(A) and the periods for which they are subject to the restrictions of section 901(j) and related provisions is provided in Revenue Ruling 95-63.
The Department of State has certified that Iraq is no longer a country described in section 901(j)(2)(A) effective June 28, 2004. Accordingly, Revenue Ruling 2004-103 modifies the prior revenue ruling to reflect this determination effective for periods after June 27, 2004.
REPORTS
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