International

March 25, 2014
How to claim foreign tax credit on property income taxes

How to claim foreign tax credit on property income taxes

Usually, no, but sometimes there is a required holding period. Normally, a U.S. person may claim a foreign tax credit for the foreign income taxes he […]
March 25, 2014
Difference between a foreign tax credit and a deduction

Difference between a foreign tax credit and a deduction

The tax savings of a credit is greater than the tax savings from a deduction. The foreign tax credit is, plainly, a credit—not a deduction. A […]
March 25, 2014
Is the Foreign Tax Credit a Refundable credit?

Is the Foreign Tax Credit a Refundable credit?

No. Section 901(a) permits a taxpayer to claim a (non-refundable) credit against his U.S. income tax. When a tax is non-refundable, the credit is not allowed […]
March 25, 2014
What Sourcing Rules Turn on an Asset's Location?

What Sourcing Rules Turn on an Asset’s Location?

The following source rules determine source according to an asset’s location, rather than the location of the payor or the payee. DEPRECIABLE PROPERTY Income from gain […]
March 25, 2014
Common income issues in international tax treaties

Common income issues in international tax treaties

BUSINESS INCOME Generally, a resident of a contracting state avoids paying tax on business income earned in the other state unless the income is attributable to […]
March 25, 2014
Tax treaties role between the U.S. and its trade partners

Tax treaties role between the U.S. and its trade partners

The primary purpose of international tax treaties is to facilitate trade and investment by lowering tax barriers to the international flow of goods and services. Secondarily, […]