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...
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...
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...
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...