TAX 9869 Lecture Notes - Lecture 33: Foreign Tax Credit

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17 Jul 2020
Indirect foreign tax credit (went away in 2017)
Kind of gone away now excpt in situation where you have subpart F
or GILTI income
Because on topic of FTC wants to show formula
When we learn about subpart F or GILTI
EXAM Q: will give info and we need to plug into the formula
Credit only applies to US CORP that owned a foreign corp
Example: Foreign corp made div distr of 100 and paid taxes in local
When US corp picks up dividend, law allowed that US corp
taxes paid on 100 would come up w/ dividend so US corp
would include:
100 of dividend plus taxes on that income that foreign
corp paid (moved up to US corp for FTC purposes)
US corp was then allowed to use that tax as a credit
This went away because: 245(A) = DRD
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