Internal Revenue Code Sections 894, 901-909: Primary U.S. tax code sections governing foreign tax credits and treaty applications for double taxation relief
FATCA: Foreign Account Tax Compliance Act - Requires foreign financial institutions to report on U.S. accounts and establishes reporting requirements for U.S. taxpayers with foreign accounts
Bilateral Tax Treaties: Agreements between the U.S. and other countries that define how income will be taxed by each jurisdiction to prevent double taxation
OECD Model Tax Convention: International guidelines that serve as a template for countries negotiating bilateral tax treaties
Treasury Regulations - Foreign Tax Credits: Detailed regulations implementing the Internal Revenue Code provisions related to foreign tax credits
Form 1116: IRS form for individuals to claim foreign tax credits and prevent double taxation on foreign-source income
Form 1118: IRS form for corporations to claim foreign tax credits and prevent double taxation on foreign-source income
Bank Secrecy Act: Requires reporting of foreign financial accounts and transactions to prevent tax evasion and money laundering
IRS Publication 514: Comprehensive guide for individuals on foreign tax credits, including calculations and limitations
Tax Court Precedents: Relevant court decisions that establish interpretations of double taxation provisions and treaty applications
