The deemed paid foreign tax credit treats a U.S.corporation that receives a foreign source dividend as if the corporation paid tax directly to a foreign jurisdiction.

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The deemed paid foreign tax credit allows a U.S. corporation to claim a credit for foreign taxes that are deemed to have been paid on foreign source income, including foreign source dividends. This credit is intended to alleviate double taxation of the same income by both the U.S. and foreign jurisdictions. The U.S. corporation is treated as if it had directly paid tax to the foreign jurisdiction on the foreign source income, and is allowed to claim a credit for the deemed foreign tax paid against its U.S. tax liability.

The Deemed Paid Foreign Tax Credit Treats a U