6.1 IntroductionArticle VI (Income from Real Property) affirms the jurisdictional powers of the source State to impose its income tax on income derived by the resident of the residence...
USA will only tax foreign business earnings if it repatriates it to USA through dividends. This policy is known as “deferral”. Deferral creates an opportunity for avoiding...
Posted by The Accounting and Tax on 01/10/2016
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
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...
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
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...
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...
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