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...
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
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...
Ref Code Section 871 (b) and 882: According to these code sections if a foreign person is engaged in a U.S trade or business, he is subject to U.S taxes for any income that is connected...
Posted by The Accounting and Tax on 12/10/2014
If a domestic corporation has a foreign subsidiary, this subsidiary will usually maintain its books and records in the currency of the country where it exists. If this subsidiary repatriates...
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...
Code Section 901: According to this code section if a U.S Citizen, a resident alien or a domestic corporation pays foreign income taxes it can claim credit for it when filing...
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...