TAX 9869 Lecture Notes - Lecture 42: Make America Great Again, Tax Deduction, S Corporation
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FTCs
o If I have a US corp, I can have a foreign DRE b/c I made a CTB election, treated
as though doesn’t exist- any income that they earn, treated as they earned it, any
tax paid, treated as though they paid the tax
▪ This tax= 901 credit, as though the US corp paid tax, DRE doesn’t exist=
arm of US company
▪ US company can pay foreign tax directly, but also if their foreign
disregarded entity or their branch pays tax, then that’s also creditable
• Diff b/w the two= the branch income/tax goes in a sep basket as
opposed to the US company pays tax directly, it depends:
o If from branch operation, goes to the branch//if other tax,
i.e. withholding tax, then doesn’t necessarily go to branch
basket, could be passive basket, general basket
Midterm: next Wednesday