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A HISTORY AND A COMPARISON
IMPLICATIONS FOR U S
ni CASE STUDY EXAMPLES
9 other sections not shown
allow alternative minimum tax Appendix Table Apportioned base company business income capital competitive computation controlled foreign corporations corporate tax deduction deemed paid credit deferral depreciation developed countries domestic double taxation earnings and profits economic effective tax rate equity financial services foreign affiliates foreign direct investment foreign investment foreign operations foreign source income foreign subsidiaries foreign tax credit France Germany Gross-up harmonized home country taxes imposed increased interest expense international investment position international tax investment abroad Italy Japan Manufacturing Subsidiary Netherlands noncontrolled section 902 OECD passive income percent of GNP provision reduce residents result revenues Royalty separate foreign tax separate limitation services income source country Study Example tax burden tax credit limitation tax policy tax system tax treaties taxable income taxation of foreign trade U.S. companies U.S. corporations U.S. economy U.S. FDI U.S. multinationals U.S. Parent Corporation U.S. rate U.S. rules U.S. shareholder U.S. source income United Kingdom withholding tax