There are 2 places that talk to it.
In the first link it is clear that beneficiaries cannot use it in succeeding years.
1. https://www.thomsonreuters.com/en-us/help/ultratax-cs/1041/allocation/allocation-of-foreign-tax-cred....
Allocation of foreign tax credit carryover
In the year the foreign tax credit is generated, the credit may be allocated to beneficiaries or be used against the estate or trust tax liability.
Any unused carryover may be used only against future estate or trust tax liability, but is no longer available for allocation to beneficiaries. Any unused foreign tax credit carryover expires at estate or trust termination.
Foreign Tax Credit Carryovers - Foreign tax credit carryovers can be used by the taxpayer's estate or heirs.
But elsewhere it also says this..i missed it earlier.
Carryovers – Generally, except as noted below, carryover deductions and credits can be used to the extent normally permitted on the decedent’s final return, but any excess does not carry over to the estate or beneficiaries. The carryovers included in this category are net operating loss (NOL), investment interest deduction, capital loss, business credit, minimum tax credit, passive loss credit, and the charitable contribution deduction.
sorry for the churn !
