International Finance and Accounting Handbook

as income derived from sources within the United States. However, in order to pre- vent international double taxation, the Unite ...

d.Foreign base personal holding-company income e.Foreign base company oil-related income 2.Insurance income 3.Illegal bribes, ki ...

rived by the Panamanian corporation are foreign base company sales income. How- ever, if the Panamanian corporation were to sell ...

Subpart F foreign personal holding company income includes investment type in- come, such as dividends, interest, rents, and roy ...

These provisions are primarily directed at the Arab boycott of Israel. Periodically, the IRS issues a notice listing countries t ...

scribed in regulations or matures within that period but is not collected within such period solely by reasons of the debtor’s i ...

subject to the alternative minimum tax, the credit cannot exceed 90% of the alterna- tive minimum tax. The economic effect of cl ...

Shipping income Dividends from each 10% to 50% U.S.-owned foreign corporation For earnings after 2002, the look-through rules ...

Passive income is income of a kind that would be Subpart F foreign personal hold- ing company income if derived by a CFC, as des ...

from euros at the exchange rate on the date the taxes were paid. F pays a dividend to P of 20,000 euros. The deemed paid credit ...

30.5 TRANSFER PRICING. Internal Revenue Code Section 482 authorizes the Com- missioner of Internal Revenue to distribute, apport ...

longer period. This interest-free period does not apply to simple loans or advances of money. Taxpayers may establish a more app ...

(b) Internal Revenue Service Activities. In recent years, the Internal Revenue Ser- vice has focused a great deal of attention o ...

(b) Transactions. For transactions in other than the functional currency, a disposi- tion of foreign currency results in the rec ...

come. Deemed distributions under Subpart F are translated at the weighted average exchange rate for the foreign corporation’s ta ...

copyrights, to the extent that the gains are contingent on the productivity, use, or disposition of the property sold and thus e ...

source capital gains and fixed or determinable income are only ECI if they are at- tributable to a U.S. trade or business. Fixed ...

large extent, the income tax treaties determine the amount of tax to be paid to the country where the income is produced and the ...

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PART VII INTERNATIONAL AUDITING CHAPTER 31 Managing the Audit Relationship in an International Context CHAPTER 32 Internal Audit ...