TAX 9869 Lecture Notes - Lecture 60: De Minimis, Foreign Tax Credit, Investment
Document Summary
If foreign base company income and gross insurance income is greater than 70% of its gross income for the taxable year, then 100% of the income will be considered foreign base company income and gross insurance income. Check sub f income to see if > 70% of the gi bc. All income has to be picked up by ussh (final exam) Foreign base company income and insurance income are less than the lesser of: F: lesser of 5% or m, pick lesser!!! Then if lesser, none= sub f= 4% of gi or ,000= de min exception. 954(b)(4): section 954(b)(4) allows a u. s. shareholder to elect to exclude from subpart f income an. Item of foreign base company income (excluding oil-related) and insurance income subject to a foreign effective income tax rate exceeding 90 percent of the maximum u. s. tax rate. > 33. 3 percent for an individual: the item"s etr is computed as:
