itonewbie
Level 15
When the Final Regulations for §904 were issued back in 2004, §1.904(b)-1(b)(3) and (e)(2) were added to carve out an exception, which, according to TD 9141, "is intended to permit taxpayers to avoid the complexity of computing the rate differential adjustments in cases where the failure to make the adjustments does not result in a significant divergence from the results contemplated by section 904(b)(2)(B)."

Based on the letter of the law, you may decide not to make the rate differential adjustment and create a limitation for FTC.
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