Foreign-source losses within a separate income basket are allocated directly against U.S.-source income without regard to income in other baskets.

Name: Foreign-source losses within a separate income basket are allocated directly against U.S.-source income without regard to income in other baskets.
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Foreign-source losses within a separate income basket are typically allocated against foreign-source income in the same basket, not directly against U.S.-source income.

Foreign-Source Losses Within a Separate Income Basket Are Allocated Directly