登入選單

返回Google圖書搜尋

Indirect Foreign Tax Credits

David J. SotosMartin J. CollinsJudy Kwok

出版	Tax Management, 2019-05-29
主題	Law / General
ISBN	16335931189781633593114
URL	http://books.google.com.hk/books?id=X7EvywEACAAJ&hl=&source=gbs_api

註釋

"Tax Management Portfolio, Indirect Foreign Tax Credits, No. 6040, contains a detailed analysis of the indirect foreign tax credit system as in effect both before and after the enactment of the 2017 tax act. The Portfolio contains a detailed analysis of former [section] 902, under which a domestic corporation may have been deemed to have paid, for purposes of the [section] 901 foreign tax credit, foreign income taxes paid by a foreign corporation from which the domestic corporate shareholder received a dividend. The Portfolio comprehensively addresses the threshold requirements to be met to apply [section] 960 under which a domestic corporation that is taxed on earnings and profits of a controlled foreign corporation under [section] 951 may be deemed to have paid foreign income taxes paid by the foreign corporation. The 2017 tax act repealed the indirect foreign tax credit under former [section] 902, and significantly amended the deemed paid credit under [section] 960; both changes are effective with respect to taxable years of foreign corporations beginning after 2017"--Portfolio description (Page (iii)).