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FOREIGN TAX CREDIT
SPECIAL TAX PROVISIONS FOR U S PERSONS
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Administration proposal Administration’s proposal allocation rules allow amount argue assets capital gain carryback carryover Code Congress controlled foreign corporation country limitation deductions deferral difﬁcult dividends earnings and proﬁts eign tax excess foreign tax exchange gain exchange rate ﬁrst ﬁxed foreign country foreign currency foreign income foreign loss foreign persons foreign source foreign subsidiary foreign tax credit foreign taxes paid foreign taxpayers forward contract functional currency gain or loss gross income income earned income tax indirect credit interest expense Internal Revenue Service loan loss recapture rule offset operations ordinary income passive income payments percent present law Puerto Rican reduce U.S. repeal separate limitation subpart F tax beneﬁt tax credit limitation tax haven income tax rate tax treaty tion transactions U.S. companies U.S. corporation U.S. dollars U.S. income U.S. lenders U.S. loss recapture U.S. persons U.S. shareholders U.S. taxable income U.S. taxpayers U.S. Virgin Islands United wage credit withholding tax