International Tax Planning for the U.S. Multinational CorporationAlan Winston Granwell |
Contents
Prepared for distribution at | 6 |
The Taxation of Passive Foreign Investment Companies | 37 |
Compliance Issues from A Corporate Perspective | 85 |
Copyright | |
7 other sections not shown
Common terms and phrases
902 corporation affiliated group amendment amount assets attributable basket income beginning after December CFC's computed Conference Report controlled foreign corporation December 31 deemed paid deemed-paid determined dividends earnings and profits export financing interest financial services entity financial services income foreign base company foreign loss foreign sales corporation foreign source income foreign tax credit FTC limitation category functional currency gross income high withholding tax included income tax intangibles interest expense item of income look-through rules mark to market paid or accrued partnership passive income payments payor PFIC prior law Prop Proposed regulation proposed technical correction purposes received or accrued recharacterized related party rents and royalties section 936 corporation separate basket separate category shipping income subpart F inclusions subpart F income tax credit limitation taxable years beginning taxes paid transactions treated U.S. dollars U.S. person U.S. shareholder U.S. source income U.S. tax withholding tax interest