### Question
How does Foreign Tax Credit define passive income?


### Answer
Under *26 U.S.C. § 904*, **passive income** is defined as:

> any income received or accrued by any person which is of a kind which would be foreign personal holding company income (as defined in section 954(c))

#### 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**

