The deemed paid credit allowed for past taxable gifts can be more than the tax actually paid.

Name: The deemed paid credit allowed for past taxable gifts can be more than the tax actually paid.
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The deemed paid credit allows for the credit of foreign income taxes on income from sources outside of the United States that have been subject to taxation. This credit can also be claimed for certain past taxable gifts, which may result in a credit amount that exceeds the actual tax paid.

The Deemed Paid Credit Allowed for Past Taxable Gifts Can