The Resource Post-ATRA : foreign tax credit problems

Post-ATRA : foreign tax credit problems

Label
Post-ATRA : foreign tax credit problems
Title
Post-ATRA : foreign tax credit problems
Creator
Subject
Language
  • eng
  • eng
Summary
Prior to the American Taxpayer Relief Act of 2012 (ATRA), there was only one effective tax rate on qualified dividends and long-term capital gains - 15%. Thus, there was only one kind of "rate differential portion" to determine the foreign tax credit (FTC). Effective 1 January 2013, ATRA created two effective tax rates - 5% and 20% - so there are now two different kinds of rate differential portions. As discussed in this article, ATRA has resulted in a series of problems regarding FTCs. Also effective 1 January 2013, the Health Care and Education Reconciliation Act of 2010 imposed a new "net investment income tax" which is based on investment income only.Therefore, if a taxpayer has foreign-source income in the form of qualified dividends or long-term capital gains, the FTC computations have become extremely complicated. This article illustrates and analyzes these problems
Citation source
In: Journal of international taxation. - New York. - Vol. 25 (2014),
http://library.link/vocab/creatorName
Yang, J.G.S
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • foreign tax credit
  • dividend
  • capital gains
  • investment income
  • tax rate
Label
Post-ATRA : foreign tax credit problems
Link
https://library.ibfd.org/custom/web/SD_PDF/scans/2014/J/JOUROFINT/10_28-37.zip
Publication
Note
20141121

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