Administrations Tax Proposals Hearings Before the Committee On Finance Unite
Administrations Tax Proposals Hearings Before the Committee On Finance Unite
United States Congress Senate Committee On Fina
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Present Law Merely Prevents Double Taxation Amidst the discussion of supposed incentives to locate plants eibroad, one must not lose sight of the fact that the purpose of the foreign tax credit is to prevent double taxation of income earned abroad. Fairness and prevention of double taxation require the present law rules to be retained. The foreign tax credit limitation prevents the foreign tax credit from exceeding the U. S. Tax which is otherwise payable on the foreign income. Congress has lon...g recognized that, in view of this limitation and out of considerations of fundeunental fairness, it is important as a general matter to consider all foreign income and foreign taxes paid in the aggregate. This permits foreign taxes in excess of the allowable limitation on one item of income to offset U. S. Tax on another item of income which was not taxed as heavily. On the average, however, the foreign tax credit may not exceed the U. S. Tax imposed on the overall foreign income. Of course. Congress has also recognized that there are some anomalous situations in which the cross-crediting described above could result in distortions .
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