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...
Posted by The Accounting and Tax on 01/06/2016
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
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...
Posted by The Accounting and Tax on 12/28/2014
The United States taxes its citizens on their world income even if they are not present in the United states. Canada taxes its residents on their would income. U.S Citizens...
Posted by The Accounting and Tax on 12/24/2014
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...
Posted by The Accounting and Tax on 12/22/2014
Foreign Corporations and non-resident aliens who have a U.S source income are subject to U.S Taxation. According to codes section 871 (b) and 882, all Foreign Persons are taxed at...
Posted by The Accounting and Tax on 12/06/2014
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...
Posted by The Accounting and Tax on 12/01/2014
For international transactions Governments have to decide which person and what income needs to be taxed. The basis for this can be personal relationship and economic relationship. Personal...
Posted by The Accounting and Tax on 10/28/2014
