If in 2006 the taxpayer has a foreign loss of $30,000 in the general limitation category,foreign-source income of $100,000 in the high withholding interest limitation category and $200,000 in the passive limitation category basket,the numerators for the FTC limitation baskets are:

Question

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The foreign loss must be apportioned pro rata to the categories with foreign-source income as follows.
High withholding interest category
$30,000 F1F1F1S1F1F1F10 ($100,000/$300,000*)= $10,000
*$100,000 + 200,000
Passive category
$30,000 F1F1F1S1F1F1F10 ($200,000/$300,000)= $20,000
The numerator of each basket is:High withholding interest category
$100,000 - 10,000 = $90,000
Passive category
$200,000 - 20,000 = $180,000
The general limitation basket will have a zero limitation after the above allocations.

If in 2006 the Taxpayer Has a Foreign Loss of $30,000