Foreign Income Tax Reform Act of 1991

[AI summary unavailable — showing source text] Foreign Income Tax Reform Act of 1991 - Amends the Internal Revenue Code to repeal the limitation of 90 percent of tax applied to the alternative minimum tax foreign tax credit. Limits the application to foreign persons of the uniform capitalization rules in determining earnings and profits. Provides that the look-through rules for controlled foreign corporations do not apply to companies with less than $1,000,000 (for five percent of gross income, if lower) in all of its separate categories. Allows the use of earnings and profits depreciation or adjustments to base the allocation and apportionment of deductible interest expenses on the adjusted basis of assets. Requires that both the assets of and the interest paid by foreign affiliates be considered in the process of allocating interest when determining the taxable foreign source income of an affiliated group. Amends source rules with respect to the sales of stock of affiliates. Provides for the treatment of gain from the sale of stock in a section 902 corporation (a domestic corporation which owns ten percent or more of voting stock of a foreign corporation) as income in a separate category in a certain proportion of earnings an…