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...
Posted by The Accounting and Tax on 02/18/2015
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
Ref Code Section 871 (b) and 882: According to these code sections if a foreign person is engaged in a U.S trade or business, he is subject to U.S taxes for any income that is connected...
Posted by The Accounting and Tax on 12/10/2014
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
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
