1. at 24; see also OECD;OECD 2015 Final Report,2017
2. Harmful Tax Practices - 2017 Progress Report on Preferential Regimes
3. Tax Treaties (CCH), says that if a foreign jurisdiction may tax the gross income under the treaty (for example, if it is attributable to a foreign PE), it is deemed for FTC purposes to be FS. The Code then requires separate basketing under � � 904(h)(10) and 904(d)(6) for any income that is treaty resourced to the foreign country. I assume (contrary to the U.S. Chamber of Commerce's position) that the FDII deduction would also be FTC-FS. So the � 904(a) foreign tax credit limit is then essentially;With regard to the � 904 foreign tax credit limitation: First, the income attributable to the foreign PE would generally be foreign source (FS) for foreign tax credit (FTC) purposes,2016