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FOREIGN TAX CREDIT SUBPART F ASPECTS SECTION 960
CAUSES AND REMEDIES
GENERAL STATUTORY SCHEME SECTION 963
6 other sections not shown
43 percent 482 allocation apply assets attributable base company income basis chain or group Chicle computed controlled foreign corporation controlling taxpayer December 31 deductions determined developed country corporation dividend domestic corporation earnings and profits effective foreign tax effective rate election Example excluded Subpart export trade income foreign base company foreign income taxes foreign source foreign subsidiary foreign tax credit foreign tax rate gain gross income Gross-up included incurs foreign taxes intangibles Internal Revenue Code Internal Revenue Service island affiliate less developed country mainland affiliate overall tax burden personal holding company Puerto Rico purposes rata minimum distribution respect Revenue Procedure sale or exchange section 367 section 482 section U82 allocation statutory table Subpart F income tainted income taken into account tax at 48 tion transaction U.S. shareholder U.S. tax United States controlling United States person United States shareholder United States tax wholly owned foreign X Corp