Tax filing season is in full force and many of my clients express a healthy fear of the IRS. Any agency that has the legal power to tax and take ALL of your money should be respected....
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...
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...