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Comparison and Assessment of the Tax Treatment of Foreign-source Income in Canada, Australia, France, Germany and the United States
註釋The report deals with selected aspects of the tax treatment of foreign-source income in Canada, Australia, France, Germany and the US. It emphasizes the structural features of each country's tax system with respect to the taxation of foreign-source income derived by resident corporations. In particular, the report focuses on the taxation of dividends from foreign corporations, controlled foreign corporation (CFC) rules, foreign investment funds rules, and source of income and expense rules.