The Resource Getting serious about curtailing deferral of U.S. tax on foreign source income

Getting serious about curtailing deferral of U.S. tax on foreign source income

Label
Getting serious about curtailing deferral of U.S. tax on foreign source income
Title
Getting serious about curtailing deferral of U.S. tax on foreign source income
Creator
Subject
Language
eng
Summary
The so-called 'deferral privilege' is one of the fundamental features of the US tax system for taxing international income. Under that privilege, a US person that conducts business or investment activity abroad through a foreign corporation generally does not pay US tax on the foreign source earnings of the foreign corporation until those earnings are distributed to the US person or the US person sells the foreign corporations stock. This article discusses and critiques the various methods for curtailing deferral of US income tax on foreign source income
Citation source
In: SMU Law Review. - Dallas. - Vol. 52 (1999) ; p. 455-530
http://library.link/vocab/creatorName
  • Peroni, R.J
  • Fleming, J.C. (Jr.)
  • Shay, S.E
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • foreign source income
  • deferral
  • foreign personal holding company
  • Subpart F income
  • passive foreign investment company
  • CFC
  • pass-through entity
Label
Getting serious about curtailing deferral of U.S. tax on foreign source income
Instantiates
Publication
Label
Getting serious about curtailing deferral of U.S. tax on foreign source income
Publication

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