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
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
Instantiates
Publication
Label
Post-ATRA : foreign tax credit problems
Publication

Library Locations

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