Does section 904(f) achieve the economies of scale in all situations?

Section 904(f) prevents the taxpayers from enjoying the double benefit of deducting foreign source loss against U.S. source income in one year and utilizing foreign tax credits against U.S. tax liability in later years. However, the scope of the section 904(f) is limited to the amount of reduction in world-wide taxable income achieved in previous years through the utilization of foreign losses. It does not address obverse situations where U.S. taxpayers incur foreign source income and U.S. source loss resulting in a net loss from world-wide operations. The tax implications to the taxpayers under these obverse situations are discussed leading to proposed solutions as enumerated in the Congressional hearings.