Who can claim a deemed paid tax credit? - A domestic “C” corporation that owns 10% or more of the voting stock and receives...
Posted by The Accounting and Tax on 01/02/2016
Who can claim a deemed paid tax credit? - A domestic “C” corporation that owns 10% or more of the voting stock and receives...
Posted by The Accounting and Tax on 12/28/2015
If foreign tax credits exceed the limitation in a given taxable year, these can be carried back one year and forward up to ten years. Excess credits on general limitation income...
Posted by The Accounting and Tax on 12/25/2015
General Income: It includes all income other than passive income. It includes most of the foreign source active business profits of domestic corporations and their foreign subsidiaries. Passive...
Bases for asserting jurisdictions Who to tax? What income to tax? Personal relationship between a taxpayer and the country This concept also applies to corporations and other type...
Gross income comes from following categories of income: Interest, Dividends, Personal Services, Rentals, Royalties, Gains from disposition of property. Leasing generates rental income....
Posted by The Accounting and Tax on 03/05/2015
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...
Ref Code Section 871 (b) and 882: According to these code sections if a foreign person is engaged in a U.S trade or business, he is subject to U.S taxes for any income that is connected...
Posted by The Accounting and Tax on 12/10/2014