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Loophole

§901 Foreign Tax Credit vs Deduction Optimization

Elect credit or deduction annually — often worth 15–37% each year in swings.

Overview

US taxpayers with foreign-source income can elect ANNUALLY to treat foreign taxes as a §901 credit (dollar-for-dollar against US tax, high-value) or a §164 deduction (against income only). Most preparers default to the credit — but in low-foreign-income or FTC-limitation years, the deduction wins. Sophisticated planners model both scenarios every year, plus §904 basket sourcing and carryforward optimization.

Best fit
Expats with foreign incomeCross-border business ownersInternational investors
Estimated impact
$5K–$50K+/yr from annual credit vs deduction optimization

Click Generate advisory deep dive for mechanics, IRC citations, a step-by-step execution plan, a worked numeric example on your profile, costs, risks, and this-week actions.

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