Reg. § 1.904(b)-2 Special rules for application of section 904(b) to alternative minimum tax foreign tax credit.
(a) Application of section 904(b)(2)(B) adjustments Section shall apply for purposes of determining the alternative minimum tax foreign tax credit under section (regardless of whether or not the taxpayer has made an election under section ).
(b) Use of alternative minimum tax rates
(1) Taxpayers other than corporations In the case of a taxpayer other than a corporation, for purposes of determining the alternative minimum tax foreign tax credit under section —
(i) Section shall be applied by using the language “section ” instead of “subsection (h) of section ”;
(ii) Section shall be applied by using the language “section ” instead of “subsection (a), (b), (c), (d), or (e) of section (whichever applies)”; and
(iii) Section shall be applied by using the language “the alternative rate of tax determined under section ” instead of “the alternative rate of tax determined under section ”.
(2) Corporate taxpayers In the case of a corporation, for purposes of determining the alternative minimum tax foreign tax credit under section , section shall be applied by using the language “section ” instead of “section ”.
(c) Effective date This section shall apply to taxable years beginning after July 20, 2004. See for a rule permitting taxpayers to choose to apply and this to taxable years ending after July 20, 2004.
[T.D. 9141, 69 FR 43316, July 20, 2004; 69 FR 61761, Oct. 21, 2004]