Canada U.S Tax Treaty Article 4 - Residency...
Posted by The Accounting and Tax on 04/01/2016
Currency translation issues:Foreign branches and subsidiaries keep their books and records in the currency of host country.Parent companies in USA are required to compute their taxable...
Posted by The Accounting and Tax on 01/27/2016
Background:U.S investors in foreign mutual funds could avoid U.S taxes. The fund itself could avoid U.S taxes because it was a foreign corporation that only derived foreign source...
Posted by The Accounting and Tax on 01/19/2016
USA will only tax foreign business earnings if it repatriates it to USA through dividends. This policy is known as “deferral”. Deferral creates an opportunity for avoiding...
Posted by The Accounting and Tax on 01/10/2016
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
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
Capital gains and losses receive a special treatment under U.S tax law. Individual capital gains and losses are netted. Non corporate taxpayer’s net capital gains get a preferred...
Posted by The Accounting and Tax on 12/23/2015
