TAX 9869 Lecture Notes - Lecture 26: Foreign Tax Credit
Document Summary
Midterm exam will be similar to the homework questions. Person met spt and became resident by obtaining gc- with both met, residency will start the first day physically present in u. s. because you"ve met spt: when you met spt test it overrides green card. You could have a split year, you could be subject to us tax for a part of the year and not the other. An individual could be nonrez alien, but to the extent they become a rez alien, subject to u. s. tax. ***important point- credit only against foreign sourced, not us. Can only take credit against foreign source income not us source income so need to know us source income. Gr: there are important rules in practice for alloc/apportioning expenses to that income. Diff types of foreign tax credits- why important, what we see in practice: a lot of additional rules that have been implemented.