Sec. 4102. Foreign tax credit limitation applied by allocating only directly allocable deductions to foreign source income
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Subsection
(b)of section 904, as amended by the preceding provisions of this Act, is amended by adding at the end the following new paragraph: For purposes of subsection (a), the taxpayer’s taxable income from sources without the United States shall be determined by allocating deductions to such income only if such deductions are directly allocable to such income. . The amendments made by this section shall apply to taxable years of foreign corporations beginning after December 31, 2014, and to taxable years of United States shareholders in which or with which such taxable years of foreign corporations end.