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...
Resident aliens in the United States are taxed on their world wide income. Nonresident aliens are taxed on their U.S source income. Code Section 7701(b)(1)(A) An alien will be considered...
Posted by The Accounting and Tax on 01/05/2015
The following items are not included in income of taxpayer for a taxation year: Amounts declared to be exempt by legislation of the Parliament of Canada (s. 81(1)(a)) Amounts received...
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...
The following items are included in income of taxpayer for a taxation year: Alimony or maintenance payments (s. 56(1)(b) and s. 56(1)(e)) Allowances for personal, living, or any...
Multinational Companies do lot of intercompany transactions. U.S manufacturers market their products in foreign countries through their subsidiaries. Domestic parent companies sometimes...
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...