The Resource New foreign tax credit rules' potential impact on the high-tax exception for Subpart F income

New foreign tax credit rules' potential impact on the high-tax exception for Subpart F income

Label
New foreign tax credit rules' potential impact on the high-tax exception for Subpart F income
Title
New foreign tax credit rules' potential impact on the high-tax exception for Subpart F income
Creator
Subject
Language
eng
Summary
This article explains the new rules that are intended to limit a corporate taxpayer's ability to claim indirect foreign tax credits, including the high-tax exception, Section 909: foreign tax credit splitter, Section 901(m): covered asset acquisition (CAA) rule, and Section 960(c): anti-hopscotch rule
Citation source
In: Tax notes international. - Falls Church. - Vol. 61 (2011),
http://library.link/vocab/creatorName
  • Carr, J
  • Changtor, C
  • Hoerner, J
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • foreign tax credit
  • Subpart F income
Label
New foreign tax credit rules' potential impact on the high-tax exception for Subpart F income
Instantiates
Publication
Label
New foreign tax credit rules' potential impact on the high-tax exception for Subpart F income
Publication

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