Technical Explanation of the Tax Simplification Act of 1991 (H.R. 2777 And S. 1394) Jcs-10-91
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pos- session (sec. 986(aXl))- This rule applies equally to foreign taxes paid directly by U.S. taxpayers, which are creditable only in the year paid or accrued (or during a carryover period), and to foreign taxes paid by foreign corporations that are deemed paid by a U.S.
55 corporation, and hence creditable, in the year that the U.S. corpo- ration receives a dividend or income inclusion.
Reasons for Simplification If each foreign income t£ix payment is required to be translated at a separate d...aily exchange rate for the day of the pajmient, the number of currency exchange rates that are relevant to foreign tax credit calculations varies directly with the frequency of foreign income tax payments. Where U.S. corporations are deemed to pay a portion of the "pool" of foreign taxes paid by foreign corpora- tions, the correct amount of tax in the pool is the product of each tax payment times the relevant translation rate. The longer the period between the time the income is earned and its repatriation (or other inclusion) to the U.S.
What to read after Technical Explanation of the Tax Simplification Act of 1991 (H.R. 2777 And S. 1394) Jcs-10-91?
You can find similar books in the "Read Also" column, or choose other free books by United States. Congress. Joint Committee On Taxation to read onlineMoreLess
To quickly assess the difficulty of the text, read a short excerpt:
pos- session (sec. 986(aXl))- This rule applies equally to foreign taxes paid directly by U.S. taxpayers, which are creditable only in the year paid or accrued (or during a carryover period), and to foreign taxes paid by foreign corporations that are deemed paid by a U.S.
55 corporation, and hence creditable, in the year that the U.S. corpo- ration receives a dividend or income inclusion.
Reasons for Simplification If each foreign income t£ix payment is required to be translated at a separate d...aily exchange rate for the day of the pajmient, the number of currency exchange rates that are relevant to foreign tax credit calculations varies directly with the frequency of foreign income tax payments. Where U.S. corporations are deemed to pay a portion of the "pool" of foreign taxes paid by foreign corpora- tions, the correct amount of tax in the pool is the product of each tax payment times the relevant translation rate. The longer the period between the time the income is earned and its repatriation (or other inclusion) to the U.S.
What to read after Technical Explanation of the Tax Simplification Act of 1991 (H.R. 2777 And S. 1394) Jcs-10-91?
You can find similar books in the "Read Also" column, or choose other free books by United States. Congress. Joint Committee On Taxation to read onlineMoreLess
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