### Question
What is the definition of high-taxed income?


### Answer
The definition of **high-taxed income** is as follows in *26 U.S.C. § 904*:

> any income which (but for this subparagraph) would be passive income if the sum of—


(i) the foreign income taxes paid or accrued by the taxpayer with respect to such income, and


(ii) the foreign income taxes deemed paid by the taxpayer with respect to such income under section 902 or 960,


  

exceeds the highest rate of tax specified in section 1 or 11 (whichever applies) multiplied by the amount of such income (determined with regard to section 78)

#### Citation:
  - *26 U.S.C. § 904*
  - Heading: **Subtitle A-Income Taxes > CHAPTER 1-NORMAL TAXES AND SURTAXES > Subchapter N-Tax Based on Income From Sources Within or Without the United States > PART III-INCOME FROM SOURCES WITHOUT THE UNITED STATES > Subpart A-Foreign Tax Credit**

