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...
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...
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...
As tax professionals, we need to be prepared to answer our client’s questions and help protect them against swindlers who are trying to steal their money and, in some...
Multinational Companies do lot of intercompany transactions. U.S manufacturers market their products in foreign countries through their subsidiaries. Domestic parent companies sometimes...
Code Section 901: According to this code section if a U.S Citizen, a resident alien or a domestic corporation pays foreign income taxes it can claim credit for it when filing...
Refer Code section 904: Limitation on Credit: Source of income rules play a very vital role when it comes to computation of foreign tax credits limitation of a taxpayer. If foreign...