TAX 9869 Lecture Notes - Lecture 30: Gross Income, Foreign Tax Credit
Document Summary
The determination of foreign branch income affects both the foreign tax credit limitation and fdii: 904(d)(1)(b) creates a separate foreign tax credit basket for foreign branch income, 250(b)(3)(a)(i)(vi) provides that foreign branch income is excluded from. Important because: creates sep basket for ftc limitation purposes, fdii: foreign derived intangible income. Its an incentive that only us corps have from earning income on sales outside us or royalties recd outside us (income coming from outside. Idea was to bring ip back to us and to be able to increase business in us: gave people an export incentive to be able to do that. Section 904 defines foreign branch income as the business profits of an. Us person attributable to one or more qualified business units as defined in section 989 in one or more foreign countries. Foreign branch income, however, does not include any passive category income.
