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IRS.gov Website
Publication 514
taxmap/pubs/p514-006.htm#en_us_publink1000224640

Carryback
and Carryover(p23)

For Use in Tax Year 2013
rule
If, because of the limit on the credit, you cannot use the full amount of qualified foreign taxes paid or accrued in the tax year, you are allowed a 1-year carryback and then a 10-year carryover of the unused foreign taxes.
This means that you can treat the unused foreign tax of a tax year as though the tax were paid or accrued in your first preceding and 10 succeeding tax years up to the amount of any excess limit in those years. A period of less than 12 months for which you make a return is considered a tax year.
The unused foreign tax in each category is the amount by which the qualified taxes paid or accrued are more than the limit for that category. The excess limit in each category is the amount by which the limit is more than the qualified taxes paid or accrued for that category.
Figure your carrybacks or carryovers separately for each separate limit income category.
The mechanics of the carryback and carryover are illustrated by the following examples.
taxmap/pubs/p514-006.htm#en_us_publink1000224641

Example 1.(p23)

All of your foreign income is general category income for 2012 and 2013. The limit on your credit and the qualified foreign taxes paid on the income are as follows:
  Your
limit
 Tax
paid
Unused foreign tax (+)
 or excess limit (−) 
2012 $200 $100−100 
2013 $300 $500+200 
       
In 2013, you had unused foreign tax of $200 to carry to other years. You are considered to have paid this unused foreign tax first in 2012 (the first preceding tax year) up to the excess limit in that year of $100. You can then carry forward the remaining $100 of unused tax.
taxmap/pubs/p514-006.htm#en_us_publink1000224643

Example 2.(p23)

All your foreign income is general category income for 2009 through 2014. In 2009, all of your foreign income was general category income, and you had an unused foreign tax of $200. Because you had no foreign income in 2008, you cannot carry back the unused foreign tax to that year. However, you may be able to carry forward the unused tax to the next 10 years. The limit on your credit and the qualified foreign taxes paid on general category income for 2009–2014 are as follows:
  Your
limit
 Tax
paid
Unused foreign tax (+)
 or excess limit (−) 
2009 $600 $800+200 
2010 $600 $700+100 
2011 $500 $700+200 
2012 $550 $400−150 
2013 $800 $700−100 
2014 $500 $550+ 50 
You cannot carry the $200 of unused foreign tax from 2009 to 2010 or 2011 because you have no excess limit in any of those years. Therefore, you carry the tax forward to 2012, up to the excess limit of $150. The carryover reduces your excess limit in that year to zero. The remaining unused foreign tax of $50 from 2009 can be carried to 2013. At this point, you have fully absorbed the unused foreign tax from 2009 and can carry it no further. You can also carry forward the unused foreign tax from 2010 and 2011.
taxmap/pubs/p514-006.htm#en_us_publink1000224645

Special rules for carryforwards of pre-2007 unused foreign taxes.(p23)

For Use in Tax Year 2013
rule
In most cases, the foreign taxes carried forward are allocated to your post-2006 separate income categories to which those taxes would have been allocated if the taxes were paid or accrued in a tax year beginning after 2006. Alternatively, you can allocate unused foreign taxes in the pre-2007 separate category for passive income to the post-2006 separate category for passive category income, and you can allocate all other unused foreign taxes in the eliminated categories to the post-2006 separate category for general category income.
taxmap/pubs/p514-006.htm#en_us_publink1000224646

Effect of bankruptcy or insolvency.(p23)

For Use in Tax Year 2013
rule
If your debts are canceled because of bankruptcy or insolvency, you may have to reduce your unused foreign tax carryovers to or from the tax year of the debt cancellation by 331/3 cents for each $1 of canceled debt that you exclude from your gross income. Your bankruptcy estate may have to make this reduction if it has acquired your unused foreign tax carryovers. Also, you may not be allowed to carry back any unused foreign tax to a year before the year in which the bankruptcy case began. For more information, see Reduction of Tax Attributes in Publication 908, Bankruptcy Tax Guide.
taxmap/pubs/p514-006.htm#en_us_publink1000224647

Time Limit on
Tax Assessment(p23)

For Use in Tax Year 2013
rule
When you carry back an unused foreign tax, the IRS is given additional time to assess any tax resulting from the carryback. An assessment can be made up to the end of one year after the expiration of the statutory period for an assessment relating to the year in which the carryback originated.
taxmap/pubs/p514-006.htm#en_us_publink1000224648

Claim for Refund(p23)

For Use in Tax Year 2013
rule
If you have an unused foreign tax that you are carrying back to the first preceding tax year, you should file Form 1040X for that tax year and attach a revised Form 1116.
taxmap/pubs/p514-006.htm#en_us_publink1000224649

Taxes All Credited
or All Deducted(p23)

For Use in Tax Year 2013
rule
In a given year, you must either claim a credit for all foreign taxes that qualify for the credit or claim a deduction for all of them. This rule is applied with the carryback and carryover procedure, as follows.
taxmap/pubs/p514-006.htm#en_us_publink1000224650

Unused taxes carried to deduction year.(p24)

For Use in Tax Year 2013
rule
If you carry unused foreign taxes to a year in which you chose to deduct qualified foreign taxes, you must compute a foreign tax credit limit for the deduction year as if you had chosen to credit foreign taxes for that year. If the credit computation results in an excess limit (as defined earlier) for the deduction year, you must treat the unused foreign taxes carried to the deduction year as absorbed in that year. You cannot actually deduct or claim a credit for the unused foreign taxes carried to the deduction year. But, this treatment reduces the amount of unused foreign taxes that you can carry to another year.
Because you cannot deduct or claim a credit for unused foreign taxes treated as absorbed in a deduction year, you will get no tax benefit for them unless you file an amended return to change your choice from deducting the taxes to claiming the credit. You have 10 years from the regular due date of the return for the deduction year to make this change. See Making or Changing Your Choice under Choosing To Take Credit or Deduction, earlier.
taxmap/pubs/p514-006.htm#en_us_publink1000224651

Example.(p24)

In 2013, you paid foreign taxes of $600 on general category income. You have a foreign tax credit carryover of $200 from the same category from 2012. For 2013, your foreign tax credit limit is $700.
If you choose to claim a credit for your foreign taxes in 2013, you would be allowed a credit of $700, consisting of $600 paid in 2013 and $100 of the $200 carried over from 2012. You will have a credit carryover to 2014 of $100, which is your unused 2012 foreign tax credit carryover.
If you choose to deduct your foreign taxes in 2013, your deduction will be limited to $600, which is the amount of taxes paid in 2013. You are not allowed a deduction for any part of the carryover from 2012. However, you must treat $100 of the credit carryover as used in 2013, because you have an unused credit limit of $100 ($700 limit minus $600 of foreign taxes paid in 2013). This reduces your carryover to later years.
If you claimed the deduction for 2013 and later decided you wanted to receive a benefit for that $100 part of the 2012 carryover, you could change the choice of a deduction for 2013. You would have to claim a credit for those taxes by filing an amended return for 2013 within the time allowed.
taxmap/pubs/p514-006.htm#en_us_publink1000224652

Married Couples(p24)

For Use in Tax Year 2013
rule
For a tax year in which you and your spouse file a joint return, you must figure the unused foreign tax or excess limit in each separate limit category on the basis of your combined income, deductions, taxes, and credits.
For a tax year in which you and your spouse file separate returns, you figure the unused foreign tax or excess limit by using only your own separate income, deductions, taxes, and credits. However, if you file a joint return for any other year involved in figuring a carryback or carryover of unused foreign tax to the current tax year, you will need to make an allocation, as explained under Allocations Between Spouses, later.
taxmap/pubs/p514-006.htm#en_us_publink1000224654

Continuous use of joint return.(p24)

For Use in Tax Year 2013
rule
If you and your spouse file a joint return for the current tax year, and file joint returns for each of the other tax years involved in figuring the carryback or carryover of unused foreign tax to the current tax year, you figure the joint carryback or carryover to the current tax year using the joint unused foreign tax and the joint excess limits.
taxmap/pubs/p514-006.htm#en_us_publink1000224655

Joint and separate returns in different years.(p24)

For Use in Tax Year 2013
rule
If you and your spouse file a joint return for the current tax year, but file separate returns for all the other tax years involved in figuring the carryback or carryover of the unused foreign tax to the current tax year, your separate carrybacks or carryovers will be a joint carryback or carryover to the current tax year.
In other cases in which you and your spouse file joint returns for some years and separate returns for other years, you must make the allocation described in Allocations Between Spouses.
taxmap/pubs/p514-006.htm#en_us_publink1000224656

Allocations Between Spouses(p24)

For Use in Tax Year 2013
rule
You may have to allocate an unused foreign tax or excess limit for a tax year in which you and your spouse filed a joint return. This allocation is needed in the following three situations.
  1. You and your spouse file separate returns for the current tax year, to which you carry an unused foreign tax from a tax year for which you and your spouse filed a joint return.
  2. You and your spouse file separate returns for the current tax year, to which you carry an unused foreign tax from a tax year for which you and your spouse filed separate returns, but through a tax year for which you and your spouse filed a joint return.
  3. You and your spouse file a joint return for the current tax year, to which you carry an unused foreign tax from a tax year for which you and your spouse filed a joint return, but through a tax year for which you and your spouse filed separate returns.
These three situations are illustrated in Figure A. In each of the situations, 2013 is the current year.
taxmap/pubs/p514-006.htm#en_us_publink1000271728

Figure A. Allocation Between Spouses

taxmap/pubs/p514-006.htm#en_us_publink1000271666
taxmap/pubs/p514-006.htm#en_us_publink1000224657

Method of allocation.(p24)

For Use in Tax Year 2013
rule
For a tax year in which you must allocate the unused foreign tax or the excess limit for your separate income categories between you and your spouse, you must take the following steps.
  1. Figure a percentage for each separate income category by dividing the taxable income of each spouse from sources outside the United States in that category by the joint taxable income from sources outside the United States in that category. Then, apply each percentage to its category's joint foreign tax credit limit to find the part of the limit allocated to each spouse.
  2. Figure the part of the unused foreign tax, or of the excess limit, for each separate income category allocable to each spouse. You do this by comparing the allocated limit (figured in (1)) with the foreign taxes paid or accrued by each spouse on income in that category. If the foreign taxes you paid or accrued for that category are more than your part of its limit, you have an unused foreign tax. If, however, your part of that limit is more than the foreign taxes you paid or accrued, you have an excess limit for that category.
taxmap/pubs/p514-006.htm#en_us_publink1000224658

Allocation of the carryback and carryover.(p25)

For Use in Tax Year 2013
rule
The mechanics of the carryback and carryover, when allocations between spouses are needed, are illustrated by the following example.
taxmap/pubs/p514-006.htm#en_us_publink1000224659

Example.(p25)

H and W filed joint returns for 2009, 2011, and 2012, and separate returns for 2010 and 2013. Neither H nor W had any unused foreign tax or excess limit for any year before 2009. For the tax years involved, the income, unused foreign tax, excess limits, and carrybacks and carryovers are general category income and are shown in Table 5.
taxmap/pubs/p514-006.htm#en_us_publink1000224660

Table 5. Carryback/Carryover

Tax year20092010201120122013
ReturnJointSeparateJointJointSeparate
H's unused foreign tax to be carried back or over, or excess limit* (enclosed in parentheses)$50$25($65)$104($50)
W's unused foreign tax to be carried back or over, or excess limit* (enclosed in parentheses)$30($20)($20)$69($10)
Carryover absorbed:     
 W's from 200920W10W
 H's from 200950H
 H's from 201015H
   ″  10W
 W's from 201210W
 H's from 201250H
W = Absorbed by W's excess limit
H = Absorbed by H's excess limit
     
* General category income only
W's allocated part of the unused foreign tax from 2009 ($30) is partly absorbed by her separate excess limit of $20 for 2010, and then fully absorbed by her allocated part of the joint excess limit for 2011 ($20). H's allocated part of the unused foreign tax from 2009 ($50) is fully absorbed by his allocated part of the joint excess limit ($65) for 2011.
H's separate unused foreign tax from 2010 ($25) is partly absorbed (up to $15) by his remaining excess limit in 2011, and then fully absorbed by W's remaining part of the joint excess limit for 2011 ($10). Each spouse's excess limit on the 2011 joint return is reduced by:
  1. Each spouse's carryover from earlier years. (W's carryover of $10 from 2009 and H's carryovers of $50 from 2009 and $15 from 2010.)
  2. The other spouse's carryover. (H's carryover of $10 from 2010 is absorbed by W's remaining excess limit.)
W's allocated part of the unused foreign tax of $69 from 2012 is partly absorbed by her excess limit in 2013 ($10), and the remaining $59 will be a carryover to general category income for 2014 and the following 8 years unless absorbed sooner. H's allocated part of the unused foreign tax of $104 from 2012 is partly absorbed by his excess limit in 2013 ($50), and the remaining $54 will be a carryover to 2014 and the following 8 years unless absorbed sooner.
taxmap/pubs/p514-006.htm#en_us_publink1000224663

Joint Return Filed
in a Deduction Year(p25)

For Use in Tax Year 2013
rule
When you file a joint return in a deduction year, and carry unused foreign tax through that year from the prior year in which you and your spouse filed separate returns, the amount absorbed in the deduction year is the unused foreign tax of each spouse deemed paid or accrued in the deduction year up to the amount of that spouse's excess limit in that year. You cannot reduce either spouse's excess limit in the deduction year by the other's unused foreign taxes in that year.