The foreign tax credit of a consolidated group can be greater than the sum of the credits of the group members when filing separately.

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When a group files a consolidated tax return, the foreign tax credit is calculated on a consolidated basis. This means that the group can offset foreign taxes paid by one member against the foreign income of another member. As a result, the foreign tax credit of the consolidated group can be greater than the sum of the credits of the group members if they had filed separately.

The Foreign Tax Credit of a Consolidated Group Can Be