A general rule for tax planning for dividend repatriation includes cross-crediting, minimizing foreign withholding taxes and considering alternative methods of repatriating earnings.
Cross-Crediting
If...
If your sole proprietorship or contract work business is booming and you can barely keep up, it may be time to hire your own employees. Once your business decides to hire its own...
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...
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...
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...