source would compute a separate foreign tax credit limitation for any income they claim benefits on using Form 1116, 'Foreign Tax Credit,' for each amount of treaty-country resourced income.
'This provision in the Beyer bill makes this favorable approach more widely available. While the new ‘short form’ may be short, the instructions explaining the workings of this rule may not be so short,' Bruce said in his explanation. 'A Joint Committee on Taxation Technical Explanation of the Beyer bill would be helpful. Likewise, Treasury regulations following enactment will be important and necessary.'"