Foreign Tax Credit Carryover and Carryback for US Expats

Josh Katz, CPA
Author: Josh Katz, CPA
Updated: November 10, 2026
Josh Katz, CPA, is the founder of Universal Tax Professionals and an international tax accountant with over 20 years of experience, including time at a Big 4 accounting firm. He specializes in US expat taxes and international tax planning for Americans living abroad.

Unused Foreign Tax Credits can generally be carried back one year or forward up to 10 years when qualifying foreign income taxes exceed the US Foreign Tax Credit limit. These credits may reduce US income tax in another year, provided the applicable income-category and IRS carryover rules are satisfied.


Americans living abroad sometimes pay more foreign income tax than they can claim as a credit on their US tax returns.

This is particularly common in countries with relatively high income tax rates, such as Germany, France, and Denmark.

Although the Foreign Tax Credit helps reduce double taxation, the amount that can be claimed in a particular year is subject to IRS limitations.

When qualifying foreign taxes exceed those limits, the unused amount may still have value. Depending on the circumstances, taxpayers can apply excess credits to a previous or future tax year rather than losing them immediately.

Key Takeaways: Foreign Tax Credit Carryovers

  • Why carryovers arise: Unused Foreign Tax Credits generally arise when qualifying foreign taxes exceed the allowable US credit.

  • Carryover periods: Excess credits can usually be carried back one year or forward 10 years.

  • Income categories: Carryovers must generally remain within the same FTC income category.

  • No automatic offset: Unused credits cannot automatically be applied against any US tax liability.

  • Forms: Form 1116 and Schedule B (Form 1116) are used to calculate and track applicable carryovers.

  • Section 951A exception: Special restrictions apply to certain foreign taxes, including those associated with Section 951A income.

Foreign Tax Credit Carryover and Carryback Rules

FeatureGeneral rule
Carryback period1 tax year
Carryforward period10 tax years
Main requirementQualifying foreign taxes exceed the FTC limitation
Income categoriesCredits generally stay within their original category
IRS formsForm 1116 and Schedule B (Form 1116)
Carryback filingGenerally Form 1040-X with revised Form 1116
ExpirationUnused credits expire after the permitted carryforward period
Special exceptionNo carryback or carryforward for Section 951A category taxes

How Does a Foreign Tax Credit Carryover Work?

A Foreign Tax Credit carryover occurs when an American taxpayer cannot use all qualifying foreign income taxes in the year they are paid or accrued because of the FTC limitation.

Instead of losing the unused amount, the taxpayer may be able to apply it against eligible US income tax in another year.

For example, an American living in Germany might pay $18,000 in qualifying German income taxes but only be allowed to claim $12,000 in Foreign Tax Credits against their US income tax for that year.

The remaining $6,000 represents excess foreign taxes that may qualify for carryback or carryforward treatment.

However, the taxpayer cannot simply deduct $6,000 from their US taxes in the following year. The amount they can use depends on the FTC limitation and available excess limitation in that year.

Example: Carrying Forward Unused Foreign Tax Credits

Suppose an American working in Germany has the following tax situation:

Tax item20262027
Qualifying foreign income taxes$18,000$8,000
FTC limitation$12,000$11,000
Current-year FTC used$12,000$8,000
Excess FTC available$6,000$0
Prior-year carryover used$0$3,000

In 2026, the taxpayer generates $6,000 in excess foreign taxes.

Assuming no amount can be used in the required 2025 carryback year, the taxpayer carries the $6,000 forward.

In 2027, the taxpayer has $3,000 of unused FTC limitation because their allowable credit limit exceeds their current-year qualifying foreign taxes.

They may use $3,000 of the 2026 carryover, leaving $3,000 potentially available for later years.

This simplified example assumes the income and taxes belong to the same FTC category and that no other limitations apply.

Foreign Tax Credit Carryback: Using Credits From the Previous Year

The IRS generally requires eligible excess foreign taxes to be carried back one year before they are carried forward.

A carryback allows taxpayers to apply unused credits against a prior year’s available FTC limitation.

For example, suppose an American living in France generates $4,000 in excess foreign taxes in 2026. If their 2025 return had $2,500 of unused FTC limitation in the same income category, they may be able to carry back $2,500 to 2025.

The remaining $1,500 may then be carried forward, subject to the applicable rules.

How to Claim a Foreign Tax Credit Carryback

Taxpayers generally follow these steps:

  1. Calculate the excess foreign taxes. Determine the unused amount for the year in which the credits originated.
  2. Review the previous tax year. Identify whether sufficient unused FTC limitation exists in the same income category.
  3. Prepare an amended return. File Form 1040-X for the carryback year, together with a revised Form 1116 and any other required supporting information.
  4. Update carryover records. Reduce the available unused credits by the amount applied to the previous year.

A carryback may result in a refund when it reduces previously paid US income tax. However, the refund is not automatic, and the applicable filing deadlines must be satisfied.

How Long Can You Carry Forward Foreign Tax Credits?

Unused Foreign Tax Credits generally remain available for up to 10 tax years after the year in which they originated.

For example, qualifying excess credits generated in the 2026 tax year may potentially be used through the 2036 tax year. If the taxpayer cannot use the remaining amount within that period, the unused credits generally expire.

The IRS also requires credits to be applied in the appropriate order, beginning with the earliest eligible year. This means taxpayers generally cannot choose to use newer credits while allowing older eligible credits to remain unused.

What Happens When Foreign Tax Credits Expire?

Expired Foreign Tax Credits can no longer be used to reduce US income tax.

For example, if a taxpayer generated $5,000 in excess credits in 2026 and only used $3,500 by the end of 2036, the remaining $1,500 would generally expire.

The carryforward period is not extended simply because the taxpayer had insufficient US tax liability or was unable to use the credits in intervening years.

Maintaining an annual record of credit balances and expiration dates helps prevent unused credits from being overlooked.

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Foreign Tax Credit Carryovers Must Stay Within the Same Income Category

One of the most important restrictions is that unused Foreign Tax Credits generally cannot be transferred between different FTC income categories.

The IRS calculates separate credit limitations for different types of foreign income.

For example, foreign employment income generally falls under the general category, while foreign interest and dividends generally fall under the passive category.

Suppose an American living in Spain has $7,000 in unused general-category Foreign Tax Credits from employment income.

In a later year, the taxpayer earns foreign investment income and owes US tax on that income.

The $7,000 general-category carryover generally cannot be used against passive-category income simply because the taxpayer has additional US tax liability.

Instead, the taxpayer must have sufficient unused FTC limitation in the same category as the original credits.

Certain income may be assigned to other categories, including foreign branch income and treaty-resourced income, depending on the applicable rules.

How to Claim a Foreign Tax Credit Carryover on Form 1116

Taxpayers generally use Form 1116 to calculate their Foreign Tax Credit and determine how much unused credit can be applied to another tax year.

Schedule B (Form 1116) is used to reconcile and track eligible foreign tax carryovers.

Step 1: Determine Your Unused Foreign Tax Credits

Review the Form 1116 calculation for the year in which the excess foreign taxes originated.

Identify the qualifying foreign taxes that exceeded the applicable FTC limitation.

Only eligible excess foreign taxes can be carried to another year.

Step 2: Check the Carryback Year

Determine whether any unused credits can be applied to the immediately preceding tax year.

The IRS generally requires eligible excess taxes to be applied to the earliest available year before carrying the remaining balance forward.

Step 3: Review Available Credits by Income Category

Identify the income category associated with each unused credit.

Compare the available carryover with the current year’s unused FTC limitation for that same category.

If multiple carryovers exist, apply them in the required chronological order.

Step 4: Complete Form 1116 and Schedule B

Enter the eligible prior-year carryover on Form 1116, line 10.

Schedule B (Form 1116) is generally required for each applicable income category when a taxpayer generates a carryover or claims a prior-year carryover, subject to the IRS filing exceptions.

The schedule tracks the original year, available balances, credits used, and remaining amounts.

Step 5: Maintain Records for Future Returns

Keep copies of prior-year Forms 1116, applicable Schedules B, foreign tax returns, and supporting payment records.

Carryovers can extend across multiple tax years, so accurate records are essential for determining how much remains available and when the credits expire.

For detailed filing requirements, the IRS Form 1116 instructions explain how to calculate and report unused foreign taxes.

When Foreign Tax Credits Cannot Be Carried Over

Not all unused foreign taxes qualify for the standard carryback and carryforward rules.

Several restrictions may prevent taxpayers from using credits in another year.

  • Foreign taxes related to excluded income. Taxes attributable to income excluded under the Foreign Earned Income Exclusion generally cannot be claimed as Foreign Tax Credits or carried forward.
  • Section 951A income. Foreign taxes assigned to the Section 951A category are not eligible for the standard one-year carryback or ten-year carryforward.
  • Simplified FTC election. Taxpayers who claim the FTC without Form 1116 under the simplified election generally cannot carry unused foreign taxes to or from that election year.
  • Foreign tax deductions. Choosing to deduct foreign income taxes rather than claim credits can restrict carryback and carryforward treatment. Special rules may also reduce the amount available in subsequent years.
  • Expired credits. Once the permitted carryforward period ends, remaining unused credits generally cannot be claimed.

These restrictions make it important to distinguish between excess qualifying foreign taxes and amounts that are not eligible for credit treatment in the first place.

Foreign Tax Credit Carryovers and the Foreign Earned Income Exclusion

Americans abroad sometimes use the Foreign Earned Income Exclusion (FEIE) and Foreign Tax Credit together to reduce their US income tax liability.

However, the two provisions interact in ways that can affect unused credits.

Foreign income taxes attributable to income excluded under the FEIE generally cannot be claimed as Foreign Tax Credits.

For example, an American living in France who excludes part of their salary under the FEIE cannot also claim an FTC for the French income taxes attributable to that excluded salary.

If the taxpayer has additional foreign income that remains subject to US taxation, qualifying foreign taxes attributable to that income may still be eligible for the FTC. The amount available for carryover must therefore be calculated after applying the relevant exclusions and adjustments.

This distinction is especially important for taxpayers who change between using the FEIE and FTC in different years.

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Common Mistakes When Tracking Unused Foreign Tax Credits

Foreign Tax Credit carryovers can be overlooked when taxpayers change accountants, move between countries, or switch tax strategies.

Common mistakes include:

  • Failing to review the carryback year: Carrying credits forward without first determining whether they must be used in the previous year.
  • Combining different income categories: Attempting to use general-category credits against passive-category income.
  • Losing track of expiration dates: Assuming unused credits remain available indefinitely.
  • Overlooking Schedule B: Failing to reconcile available credits and balances when required.
  • Claiming credits on excluded income: Including foreign taxes attributable to income excluded under the FEIE.

Even when a taxpayer owes no US income tax in a particular year, maintaining accurate FTC records may be useful if qualifying excess credits are available for future years.