Chapters 4 - Foreign Source Income Worldwide Income X...

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INTERNATIONAL TAXATION Foreign Tax Credit
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General Concepts Creditable Foreign Income Taxes Direct Foreign Tax Credit – Branches Deemed Foreign Tax Credit – Subsidiaries (Dividends)
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Creditable Foreign Income Taxes Tax vs. payment (oil royalties) Accrual basis, when incurred Cash basis, when paid or accrued (irrevocable election) Income Tax or in-lieu of income taxes (withholding) Allocated between Passive and General classes of income
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Direct Foreign Tax Credit Lesser of: Foreign Tax Credit limitation for U.S. citizens and Resident Aliens=
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Unformatted text preview: Foreign Source Income Worldwide Income X Precredit U.S. Tax = Foreign Tax Credit Limitation Or Creditable Foreign Taxes Paid Special Rules: Domestic Loss reduces foreign source income Indirect Foreign Tax Credit Deemed Paid Credit Corporations w/ > 10% ownership Special rules for tiered ownership Post 86 Foreign Taxes X Dividend Received Paid Post 86 E&P of Sub Income is grossed up by the deemed credit (Section 78) Taxes flow up from lower tier corporations see page 117...
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This note was uploaded on 09/16/2011 for the course TAX 6527 taught by Professor Andrewjudd during the Spring '11 term at University of Central Florida.

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Chapters 4 - Foreign Source Income Worldwide Income X...

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