Taxpayers who have accrued or paid foreign income taxes in a U.S. possession or foreign country can generally deduct those taxes from their U.S. tax on foreign source income. The foreign...
Posted by Jim McClaflin, EA, NTPI Fellow, CTRC on 11/17/2022
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
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...
Bases for asserting jurisdictions Who to tax? What income to tax? Personal relationship between a taxpayer and the country This concept also applies to corporations and other type...
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 (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...