Tax effects of the repeal of sanctions against South Africa.

• Author: Gordon, Richard A.

Earlier this year President Bush lifted five-year-old federal trade and investment sanctions against South Africa. Therefore, taxpayers who have operations in South Africa or who plan to invest in South Africa should be aware that the denial of a foreign tax credit (FTC) under Sec. 901(j)(2)(C)(i) for taxes paid to South Africa is removed as of July 10, 1991. The removal of the prohibition allows U.S. taxpayers to claim an FTC for any income tax paid to South Africa (instead of being able to claim only a deduction). The IRS is working on transition rules addressing the removal of the FTC prohibition and should issue a ruling sometime this year.

Income earned in South Africa by a controlled foreign corporation (CFC) as of July 10, 1991 is no longer...