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Planning for outbound transactions

Planning for outbound transactions

Planning for outbound transactions...

Posted by The Accounting and Tax on 02/11/2016

International tax tax issue host country taxation issues tax treaties structuring foreign operations low-tax foreign jurisdictions high-tax foreign tax jurisdictions debt financing local tax incentives transfer pricing tax treaties foreign hold
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How to plan for dividend repatriation?

How to plan for dividend repatriation?

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

International tax foreign tax credit deemed paid foreign tax credit dividends foreign operations cross-crediting residual tax look through rules repatriation of earnings alternative to dividend repatriation minimizing foreign withholding taxes a
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Foreign Tax Credit Deemd Paid - USA

Foreign Tax Credit Deemd Paid - USA

Deemed Paid Foreign Tax Credit U.S.A If a domestic Corporation receives dividends from foreign Corporation it usually cannot claim a deduction for dividends received. These dividends...

Posted by The Accounting and Tax on 12/01/2014

Foreign Tax Credit resident alien Domestic Corporation limitation of foreign tax credit dividends rent royalties controlled foreign corporation Code 904 Code 902 Tier Corporations Voting Stock Sub Part F high tax rate tax credit.
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