INTERNATIONAL TAXATION
How are foreign branches taxed
US taxes on income when earned
For _____ that are taxed immediately, what amount of
deduction are they allowed to take?
branches; lesser of foreign taxed imposed and foreign tax
credit
What is the foreign tax credit
Pre credit US tax X Foreign source income/total income
How are foreign subsidiaries taxed
they are taxed in foreign countries, earnings are not taxed
until brought back to the US in forms of dividends
In what system are citizens and residents taxed on all
their income
worldwide tax system
in what system are citizens and residents taxed on
income only earned within its borders
Territorial tax system
When a _____ is only taxed by the host country,
earnings are not taxed in US until they are brought
home in the form of ______. What makes up for
this_____
subsidiary; dividends; dividends received deduction
what can you not include in the foreign tax credit
dividends received deduction
Interest is taxed based on