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...
Posted by The Accounting and Tax on 12/21/2015
After computation of creditable foreign income taxes, next step is to compute foreign tax credit limitation. Example: USAco has U.S source income = 200 Foreign source taxable...
Posted by The Accounting and Tax on 12/18/2015
The United States restricts the credit to foreign income taxes that duplicate the U.S income tax against which the credit is taken. Under code section 901, a foreign levy must...
Posted by The Accounting and Tax on 12/18/2015
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...
Posted by The Accounting and Tax on 10/13/2015
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...
Posted by The Accounting and Tax on 02/18/2015
Code Section 7701 (b)(2)(A)(iii) U.S residency start date depends on two things: ü Residency is established under the green card test. ü Residency is established...
Posted by The Accounting and Tax on 01/23/2015
U.S Internal Revenue code does not give any special status to RRSP, TFSA, RESP, RPP or DSPS plans. If an employer contributes to a registered pension plan or a deferred profit-sharing...
Posted by The Accounting and Tax on 01/10/2015
Resident aliens in the United States are taxed on their world wide income. Nonresident aliens are taxed on their U.S source income. Code Section 7701(b)(1)(A) An alien will be considered...
Posted by The Accounting and Tax on 01/05/2015
