Soren Lindqvist, a US citizen, computes his 2024 foreign tax credit on Form 1116. His US tax before the credit is 30,000 dollars and his total taxable income is 150,000 dollars. His foreign-source taxable income falls into two separate limitation categories: 20,000 dollars of passive category income, on which he paid 8,000 dollars of foreign tax, and 40,000 dollars of general category income, on which he paid 6,000 dollars of foreign tax. The Section 904 limitation for each category equals the pre-credit US tax multiplied by that category's foreign-source taxable income divided by total taxable income, and the credit for each category is the lesser of the foreign tax paid in it or its limitation. Ignoring any carryovers, what total foreign tax credit may Soren claim for 2024?
- A14,000 dollars, being the full amount of foreign income tax he paid across both the passive and the general limitation categories during 2024.
- B10,000 dollars, being 4,000 dollars allowed in the passive category and the full 6,000 dollars allowed in the general category after each separate limitation. Correct
- C12,000 dollars, computed by pooling both categories of foreign income into a single Section 904 limitation of 30,000 dollars times 60,000 dollars over 150,000 dollars.
- D8,000 dollars, computed by applying one Section 904 limitation using only the 40,000 dollar general category income fraction and capping the whole credit there.
Why A is wrong: This ignores the Section 904 limitation entirely and simply credits all foreign tax paid, which the per-category limitation does not permit.
Why B is correct: The passive limitation is 30,000 times 20,000 over 150,000 equals 4,000 (capping the 8,000 paid), and the general limitation is 30,000 times 40,000 over 150,000 equals 8,000 (so the 6,000 paid is fully allowed), totalling 10,000.
Why C is wrong: This combines the passive and general income into one limitation, but Section 904 requires a separate limitation to be applied to each category.
Why D is wrong: This applies a single limitation based only on the general category income and wrongly caps the entire credit, instead of running each category separately.