SOF III - 1081 Southern Financial LLC deduction (subject to the limitations generally applicable to deductions) for their share of such foreign taxes in computing their U.S. federal income taxes. Tax Credit Limitations. Each Investor's share of any foreign income or withholding tax imposed on the income and gains of the Onshore Feeder Fund generally will be treated as a foreign income tax that the Investor may elect to deduct in computing its U.S. federal income tax liability or, subject to generally applicable limitations and conditions under the Code, to credit against such liability. These limitations include a rule limiting the amount of the credit to the U.S. tax liability that otherwise would be imposed on foreign source income of the Investor in the same category as the income giving rise to the foreign tax (as determined after deducting related expenses, including an allocable portion of the Investor's overall interest expense). In many cases, capital gains of the Onshore Feeder Fund will be treated as U.S. source income and therefore an Investor may not be to use a foreign tax credit for any foreign tax that might be imposed on the gains. Further, U.S. Holders will not generally be entitled to an indirect foreign tax credit with respect to foreign taxes paid by a portfolio company treated as a foreign corporation for U.S. federal income tax purposes. Certain losses arising from the Onshore Feeder Fund may be treated as foreign source losses, which could reduce the amount of foreign tax credits otherwise available. Qualified Dividends and Certain Capital Gains. Reduced U.S. federal income tax rates currently apply to (a) capital gains received by individuals and other non-corporate taxpayers and (b) "qualified dividend income" received by individuals and other non-corporate taxpayers from certain domestic and foreign corporations. The reduced rates applicable to capital gains will also apply to capital gains recognized by Investors wh