Which of the following statements is true?

A$.$ Excess foreign taxes from the general foreign income category may offset U$.$S$.$ income taxes from the

passive foreign income category.

B$.$ Excess foreign taxes may be carried back one year and$/$or carried forward ten years.

C$.$ Foreign taxes paid to one country can never be used to offset U$.$S$.$ taxes on income earned in another

country.

D$.$ Both a and b$.$