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Excerpt from Associated Telephone and Telegraph Co.,
306 F.2d 824 (2nd Cir. 1962)

The basic policy underlying all the foreign tax credit provisions is the elimination of double taxation. . . . But there is a well-established limitation on this policy. It is not the purpose of this foreign tax credit allowance to relieve taxpayers from bearing the full United States tax burden attributable to income arising from sources within this country. . . . Moreover, the purpose of Section 902(a) [deemed paid foreign tax credit] is to extend the same tax treatment to a domestic corporation with a foreign subsidiary as is accorded a domestic corporation with a foreign branch within the same corporate shell.