951b 957 and 958 48 Sec 245A 49 Secs 951 964 GILTI means with respect to any US

951b 957 and 958 48 sec 245a 49 secs 951 964 gilti

This preview shows page 16 - 18 out of 38 pages.

951(b), 957, and 958. 48 Sec. 245A. 49 Secs. 951-964. GILTI means, with respect to any U.S. shareholder, the excess of its pro rata share of certain CFC income over a 10-percent return (reduced by certain interest expense incurred by CFCs) on its pro rata share of the aggregate of the average quarterly adjusted bases in certain depreciable tangible property of each CFC with respect to which it is a U.S. shareholder. 50 The deduction for GILTI is not available for Regulated Investment Companies (“RIC”) or REITs. 51 Foreign income taxes limited in a tax year may be carried back one year or forward ten years. A 20- percent foreign tax credit disallowance applies to GILTI. Sec. 951A. Foreign tax credits are not available for foreign taxes paid or accrued with respect to dividends qualifying for the 100-percent dividends-received-deduction. Sec. 245A. 52 A corporation’s FDII is its deemed intangible income multiplied by the percentage of its income (computed with certain exceptions) derived from serving foreign markets. A corporation’s deemed intangible income is the excess of its income (computed with certain exceptions) over a 10-percent return on the aggregate of its average quarterly adjusted bases in certain depreciable tangible property. The deduction for FDII is not available for RICs or REITs. Sec. 250.
15 Like individuals, corporations may reduce their tax liability by any applicable tax credits. 53 The three largest dollar amount credits are the research credit, the low income housing tax credit, and the renewable electricity production credit, which target intangible investment, real property investment, and electricity production, respectively. 54 The research credit is generally available with respect to incremental increases in qualified research. 55 A research tax credit is also available with respect to corporate cash expenses paid for basic research conducted by universities (and certain nonprofit scientific research organizations) above a certain floor. 56 Finally, a research credit is available for a taxpayer’s expenditures on research undertaken by an energy research consortium. 57 The low-income housing tax credit may be claimed over a 10-year period by owners of certain residential rental property for the cost of rental housing occupied by tenants having incomes below specified levels. 58 The amount of the credit for any taxable year in the credit period is the applicable percentage of the qualified basis of each qualified low-income building. The qualified basis of any qualified low-income building for any taxable year equals the applicable fraction of the eligible basis of the building. An income tax credit is allowed for the production of electricity from qualified energy resources at qualified facilities (the “renewable electricity production credit”). Qualified energy resources comprise wind, closed-loop biomass, open-loop biomass, geothermal energy, solar energy, small irrigation power, municipal solid waste, qualified hydropower production, and marine and hydrokinetic renewable energy. Qualified facilities are, generally, facilities that

  • Left Quote Icon

    Student Picture

  • Left Quote Icon

    Student Picture

  • Left Quote Icon

    Student Picture