The income specified by Cabinet Order prescribed in Article 95, paragraph (4), item (xvii) (Foreign Tax Credit) of the Act is the following income:

The transactions specified by Cabinet Order prescribed in Article 95, paragraph (5) (Foreign Tax Credit) of the Act are guarantees of obligations pertaining to borrowing of funds or other transactions (including acts of assuming an obligation that are equivalent to a guarantee of obligations).

①The things specified by Cabinet Order as equivalent to interest prescribed in Article 95, paragraph (7) (Foreign Tax Credit) of the Act are discount charges on bills and other things whose economic nature is equivalent to interest.

②The events specified by Cabinet Order prescribed in Article 95, paragraph (7) of the Act are the following events:

①Where, in any year within the seven years starting from the year following the year in which the application of Article 95, paragraphs (1) through (3) (Foreign Tax Credit) of the Act was received with respect to the amount of foreign income tax that a Resident became liable to pay, the amount of that foreign income tax is reduced, for the year in which the date on which that amount is to be reduced falls for that Resident (hereinafter in this Article referred to as the "year of the reduction"), an amount equivalent to the reduced amount of credit-eligible foreign income tax is to be deducted from the amount of credit-eligible foreign income tax that that Resident is to pay in the year of the reduction (referred to in paragraph (3) as the "credit-eligible foreign income tax to be paid"), and the provisions of Article 95, paragraphs (1) through (3) of the Act apply to the amount after that deduction.

②The reduced amount of credit-eligible foreign income tax prescribed in the preceding paragraph means, of the amount by which the amount of foreign income tax was reduced in the year of the reduction of a Resident, the amount equivalent to the remainder obtained by deducting the amount listed in item (ii) from the amount listed in item (i):

③In the case referred to in paragraph (1), where there is no credit-eligible foreign income tax to be paid for the year of the reduction, or where that credit-eligible foreign income tax to be paid is less than the reduced amount of credit-eligible foreign income tax prescribed in the preceding paragraph (hereinafter in this paragraph referred to as the "reduced amount of credit-eligible foreign income tax"), the full amount of that reduced amount of credit-eligible foreign income tax, or the amount equivalent to the portion of that reduced amount of credit-eligible foreign income tax exceeding that credit-eligible foreign income tax to be paid, respectively, is to be deducted from the amount exceeding the credit limit prescribed in Article 224, paragraph (6) (Maximum Carry-Over Credit, etc.) for each year within the three years up to and including the year preceding the year of the reduction (excluding the amount of the portion deemed not to exist in each year up to and including the year preceding the year of the reduction under paragraph (3) of that Article or Article 225, paragraph (3) or (4) (Carry-Over, Credit-Eligible Foreign Income Taxes, etc.); hereinafter in this paragraph referred to as the "amount exceeding the credit limit"), and the provisions of Article 95, paragraph (3) of the Act apply to the amount after that deduction. In this case, where there is an amount exceeding the credit limit for two or more years, the deduction is made first from the amount exceeding the credit limit for the oldest year, and where there remains an amount that cannot be fully deducted, the deduction is made successively from the amount exceeding the credit limit for newer years.

①The amount calculated as specified by Cabinet Order prescribed in Article 95-2, paragraph (1) (Special Provisions on Foreign Tax Credits Related to the Special Provisions on Capital Gains and Similar Income upon Departure from Japan) of the Act (including where applied mutatis mutandis pursuant to paragraph (2) of that Article; the same applies hereinafter in this Article) is to be the amount obtained by deducting, from the amount of foreign income tax imposed on income for the period that forms the basis for calculating the tax base of that foreign income tax under the provisions of laws and regulations relating to foreign income tax (meaning foreign income tax prescribed in Article 95-2, paragraph (1) of the Act; the same applies hereinafter in this paragraph) imposed on income arising from the transfer (meaning the transfer prescribed in Article 60-2, paragraph (4) of the Act; the same applies in item (ii) and paragraph (4)) or settlement of Securities and similar interests (meaning Securities and similar interests prescribed in Article 60-2, paragraph (1) (Special Provisions on Capital Gains upon Departure from Japan) of the Act; the same applies in paragraphs (4) and (5)) or of contracts pertaining to an unsettled margin transaction or similar transaction prescribed in paragraph (2) of that Article or an unsettled derivatives transaction prescribed in paragraph (3) of that Article (hereinafter in this paragraph and the following paragraph referred to as "covered assets"), or the transfer thereof by way of gift or inheritance with limited liability (meaning gift or inheritance with limited liability prescribed in paragraph (8) of that Article; the same applies in paragraph (4)) (hereinafter in this paragraph referred to as "transfer, etc."), the amount of foreign income tax imposed on income for that period on the assumption that there were no income arising from the transfer, etc. of those covered assets (excluding income falling under the domestic source income specified in each item of Article 164, paragraph (1) (How Nonresidents Are Taxed) of the Act according to the category of Nonresident listed in those items) (or, in a case listed in the following items, the amount specified in the relevant item according to the category of case listed in that item).

②In calculating the maximum credit prescribed in Article 95, paragraph (1) (Foreign Tax Credit) of the Act for the year that includes the date of departure from Japan (meaning departure from Japan prescribed in Article 60-2, paragraph (1) of the Act; the same applies in paragraph (4)) where the provisions of Article 95-2, paragraph (1) of the Act apply, income arising from the transfer or settlement of covered assets deemed to have been carried out under the provisions of Article 60-2, paragraphs (1) through (3) of the Act (including where those provisions are applied by replacing terms pursuant to paragraph (8) of that Article (including where applied mutatis mutandis pursuant to paragraph (9) of that Article)) is treated as falling under the foreign source income listed in the items of Article 221-2 (Amount of Foreign-Source Income), and the provisions of that Article apply.

③The provisions of Article 60-2, paragraph (11) of the Act apply mutatis mutandis to the application of Article 95-2, paragraph (1) of the Act.

④The provisions of Article 170, paragraph (8) (Special Provisions on Capital Gains upon Departure from Japan) apply mutatis mutandis to the determination of whether, where an individual (including the individual's heir) who receives the application of Article 95-2, paragraph (1) of the Act with respect to the income tax for the year that includes the date of departure from Japan has, after the time of that departure from Japan, transferred Securities and similar interests or transferred them by way of gift or inheritance with limited liability, the Securities and similar interests so transferred fall under the Securities and similar interests that the person held at the time of that departure from Japan.

⑤The provisions of Article 170, paragraph (9) apply mutatis mutandis to the portion of the former Securities and similar interests that gave rise to the acquisition of the acquired Securities, etc., in the case where, with respect to Securities and similar interests held by the individual prescribed in the preceding paragraph (hereinafter in this paragraph referred to as "former Securities and similar interests"), a cause listed in the items of Article 60-2, paragraph (11) of the Act as applied mutatis mutandis in paragraph (3) has arisen, and the Securities and similar interests acquired by reason of that cause (hereinafter in this paragraph referred to as "acquired Securities, etc.") are deemed under paragraph (11) of that Article to have continued to be owned.