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...
Gross income comes from following categories of income: Interest, Dividends, Personal Services, Rentals, Royalties, Gains from disposition of property. Leasing generates rental income....
Posted by The Accounting and Tax on 03/05/2015
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...
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...
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