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Foreign Tax Credit paid by a CFC to an indivudal

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    #1

    Foreign Tax Credit paid by a CFC to an indivudal

    Client is an individual that is a US person and owns 100% of a Controlled Foreign Corporation. He receives a dividend. Is my understanding correct that he gets a 901 credit for any withholding of taxes in the foreign country but does not get any 902 indirect credit due to the fact that it has been repealed and furthermore he is an individual. Section 245A will not apply to him as he is an individual.
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