Source of income can have significant impact on calculation of foreign tax credit limitation.
Formula for foreign tax credit limitation
= Pre-credit U.S tax x foreign...
Code Section 7701 (a)(30)
U.S citizens are U.S Persons and Citizens of foreign countries are U.S Persons who meet either of the following two tests:
Green Card test
Substantial...
The following items are included in income of taxpayer for a taxation year:
Alimony or maintenance payments (s. 56(1)(b) and s. 56(1)(e))
Allowances for personal, living, or any...
If a taxpayer has personal relations with one country (Home) and derives income from another country (Host) it can cause a double taxation issue. The host country will most likely...
Deemed Paid Foreign Tax Credit U.S.A
If a domestic Corporation receives dividends from foreign Corporation it usually cannot claim a deduction for dividends received. These dividends...