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    Practical Tax-Strategies

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    Practical Tax-Strategies

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    practical Tax-strategies

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    Practical Tax-Strategies

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    CHECKPOINT Practical Tax Strategies vaminetinat feumerat gee veces ‘towigntar UNDER TI US tanpayrs are generally subject to US. taxon thee workdwde come ot maybe proved 3 tax cred for fovegh income thes paid or 2c ‘ued. The main purpose ofthe foreign tacit Isto miiate the Gouble uation of foreign Source income that mip occur ifsuch income taxed by bot the United Sites and «Tren ‘Sounty An nd US.taxpayer may receive 1c foreign tox ret er orig ates tat Thetaxpaye pasta foreign goverment A US. ‘orporation that rs at ent 10% of tock ina Tove conporation by voteo vale) may rive an indnee” or “derol” fright te oe feel anes pid by hat bday. TRC Seton 90 iis he orc ts net toforeg tases imposed on income, war prof iteor exes profits” IRC Section 63 extends the credit foreign toxs imposed in lew of income tax Upntl very rece. in onder {orbe creditable under ether Ssction 901 oF ‘Sctian 7 og oe ly mat hea ex ta eguites a compulsory ayment punto theauherly afore ountey f0 levy taxes” The fax also must be level by foreign country pursuant cota E NEW FINAL REGULATIONS Ingouthonty, ntsome oer authority suchas pealies ines, and eastom dutes. A Foregn fees nova tax tothe exten that an ett re ‘eves "special economic benef fon fr ‘ign country inexchange ora payment. ‘Only compulsory payments are considered payments oftas A payment snot compulsory to theexten! ha the amount paid exceds the stsount of tality under foreign le for thetax Hnaly,aU'S taxpayer must exhaustall effective and practical medi, including in ‘ocation of competent authonty procedires sable under applicable ax treats, to ‘dace, overtime. he US. taxpayer’ ability or Teveign tax What amount of foreign taxes s creitable? foreign tre (under ether Sct 901 of {able foegn tars pal oracenied” Ananount ‘ft fo considered pao the exten hal" ‘sreatonaly certain that an ion il be re And redid. etal, abated or fren.” NIHON PD ong pe al ln La ha uni yr et ee reli eer pence tee tte fer ‘coax potag anata pon doc) hadinea och tyne me Cs stajctenate I Section 6 as arene by the 2017 tax Cuts and Jabs Act, adopts a new “prop: rly attebutable to” stanford to determine {he amount of oretgn tates deemed paid by US. shareholders of somal foreign cor porations (CFCS). Section 9603) provides, that U'Scosporate shareholders that include “any item of cone under Section 9511aKt)" with Zespect to any CEC shall be deemed to have paid "0 mach of ich foreign corpora tion's ovegn taxes ax ae propery atibute bet such tem of income” Under thisstar Aas a CHC shareholder must gros up the foreign income inelvsion moun to the For ‘ign axes propeity atitutable toi under TRE Section 78" Thivisdoneto prevent te us offcegn te reds to reduce tax on US, source income Thisis express bythe along forme US. taxon worlwide income prior > aiming fregn tax roi Xoregh source ‘wrk tasaleinsome Foreign tax credit limitation and baskets ‘The foreign tax cred gency linited toa taxpayers US. tax habit on ie foreign soure taxhle income computed under US tax accountng principles This Limitation ks imputed by maltipvingauxpayer'stoial US, taclibity (prior othe oreiga ax ced) that yearby the rai of te taapayer oreiga sour taxable income a that yar fo the tax payers worldwide taxable income in that The limitation fap seprael to spe

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