The Resource Foreign tax credits : substance prevails over form, but uncertainty remains

Foreign tax credits : substance prevails over form, but uncertainty remains

Label
Foreign tax credits : substance prevails over form, but uncertainty remains
Title
Foreign tax credits : substance prevails over form, but uncertainty remains
Creator
Subject
Language
eng
Summary
This article examines the Supreme Court decision resolving the conflict between the circuits as to whether a one-time windfall tax imposed by the United Kingdom on the difference between two values was a creditable income or excess profits tax under Code Sec. 901. The Court held that the United Kingdom's windfall tax did qualify as a creditable income/excess profits tax under Code Sec. 901
Citation source
In: Taxes - the tax magazine. - Chicago. - Vol. 92 (2014),
http://library.link/vocab/creatorName
Doering, J.A
Language note
English
http://library.link/vocab/subjectName
  • case law
  • foreign tax credit
  • windfall profits tax
  • excess profits tax
  • substance over form
  • retroactivity
Label
Foreign tax credits : substance prevails over form, but uncertainty remains
Instantiates
Publication
Label
Foreign tax credits : substance prevails over form, but uncertainty remains
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
Processing Feedback ...