Simplified 951A part 3 FTC:  Deemed Paid Foreign Tax Credit
Channel: International Tax
Date: 16/05/2019

The deemed paid foreign tax credit under §960 applies to 951A inclusions.  This video discusses this with fairly simple example using 3 CFCs.

Second video is at:  https://youtu.be/1RLStXjdUv4
Fourth video is at:  https://youtu.be/g92DonOERfw

Here's what's in this video:
00:00  Intro & recap
00:49  Inclusions are post-tax amounts
00:59   Deemed paid credit basics
01:47  Allocate & apportion tax
02:42  Reduce tax by inclusion ratio & to 80%
03:22  Example
08:25  962 election for individuals
06:10  Example of planning
09:23  Tracking