(a) through (f) [Reserved]. For further guidance, see § 1.901-1(a) through (f).

(g) Taxpayers to whom credit not allowed. Among those to whom the credit for taxes is not allowed are the following—

(1) Except as provided in section 906, a foreign corporation;

(2) Except as provided in section 906, a nonresident alien individual who is not described in section 876 (see sections 874(c) and 901(b)(4));

(3) A nonresident alien individual described in section 876 other than a bona fide resident (as defined in section 937(a) and the regulations thereunder) of Puerto Rico during the entire taxable year (see sections 901(b)(3) and (4)); and

(4) A U.S. citizen or resident alien individual who is a bona fide resident of a section 931 possession (as defined in § 1.931-1T(c)(1)), the U.S. Virgin Islands, or Puerto Rico, and who excludes certain income from U.S. gross income to the extent of taxes allocable to the income so excluded (see sections 931(b)(2), 933(1), and 932(c)(4)).

(h) [Reserved]. For further guidance, see § 1.901-1(h).

(i) [Reserved]. For further guidance, see § 1.901-1(i).

(j) Effective date. This section shall apply for taxable years ending after October 22, 2004.