The primary aim of the tax provisions is to prevent multinationals from abusing foreign tax credits.
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Donnelley asked for a refund based on carrying back unused research credits and foreign tax credits.
As a result, the company might not expend resources to challenge foreign tax assessments.
Forcing U.S. corporations to pay more foreign tax will only increase our already huge deficit.
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Switzerland, for example, has begun helping out foreign tax offices, including revealing the identities of account holders.
In an interview published on Sunday, Luc Frieden said he wanted to "strengthen co-operation with foreign tax authorities".
But until 2005, this foreign tax credit could offset only 90% of the alternative minimum tax they owed.
You pay the tax to Canada but can claim a foreign tax credit with the Internal Revenue Service.
At September 30, 2012, approximately 52% of our cash and cash equivalents were domiciled in foreign tax jurisdictions.
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The answer, if you can believe it, is that they want American banks to help enforce foreign tax law.
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The scheme is tied to a foreign tax shelter designed by an arm of American International Group (AIG).
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Equally worrisome, it creates a system allowing foreign tax collectors to cross borders.
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It aimed to get jurisdictions to collect better information and to share it with foreign tax authorities when necessary.
But unless Congress changes the law, the IRS is not responsible for helping foreign tax collectors squeeze more money out foreign taxpayers.
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U.S. law prevents double taxation by allowing a credit for foreign tax on income which is also subject to U.S. income tax.
Yet filing tax returns in multiple nations and claiming foreign tax credits is an imperfect process that often results in tax mismatches.
First, for years prior to 2010, he may have had no U.S. tax liability against which to apply a foreign tax credit.
Apple's figures for foreign tax appear on page 61 of its form 10-K filing with the US Securities and Exchange Commission (SEC).
Croix subsidiary is the third such Ocwen-related entity to be domiciled in a foreign tax haven, joining others in Luxembourg and the Cayman Islands.
All passive income, which has already been taxed, is exposed to double taxation for which even the foreign tax credit is of no use.
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While the unused foreign tax credit can be applied to future years, it is unlikely that Mr. Johnson will ever see the majority of it.
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But often tax driven transactions are legal and are manipulations of complex tax rules, sometimes a blend of U.S. and foreign tax rules and tax treaties.
While they may claim foreign tax credits for taxes paid elsewhere, they still end up with high U.S. taxes even if they pay low rates overseas.
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On January 7, the tax-collection bureaucracy proposed a regulation that, if implemented, would force American financial institutions to put foreign tax law above US tax law.
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For this reason, the foreign tax credit has never been defined as a subsidy by any administration or Congress in any comprehensive study examining energy tax policy.
But tax experts say that normally softens when the country the citizen works in has a treaty with the U.S., because certain foreign tax credits may be allowed.
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While there will be a lot of emphasis on Libya, also look for discussions on trade and tariffs, offshore accounts and foreign tax credits for corporations and individuals.
You will be able to deduct these from your U.S. tax bill, yet make sure the credit for foreign tax paid won't open you up to the dreaded alternative minimum tax.
Sir James explicitly rules out co-operation in foreign tax-evasion cases.
At least when the income is sourced to the U.K., the athlete can partially alleviate the tax hit by taking a foreign tax credit on their U.S. income tax return.
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