sentences:  Under such systems, generally the amount of credit is the foreign taxes paid by the foreign corporation times the fraction of earnings distributed to the shareholder as a dividend.Generally, the amount of dividend is "grossed up" for the amount of available credit, before limitations, effectively charging the shareholder with home country tax for the income on a pre-tax basis.The deemed paid credit mechanism may be applied up the chain of corporate distributions, and may be subject to ownership limitations.