TAX 9869 Lecture Notes - Lecture 33: Foreign Tax Credit

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17 Jul 2020
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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
county.
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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