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
One Step at a Time,Every Big Enterprise Starts Small Opening up the business of your choice is not a walk in the park. It is not enough...
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
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...
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...
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...