Statistics of Income, 1974: Supplemental Report : International Income and Taxes : Foreign Tax Credit Claimed on Corporation Income Tax ReturnsDepartment of the Treasury, Internal Revenue Service, Statistics Division, 1980 - 158 pages |
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Common terms and phrases
accrued and deemed area or country areas and DISC ASSETS OF $250 combinations of countries Controlled Foreign Corporations corporations and DISCS countries shown country and DISC DISC dividends Form DISC Dividends-Continued Money Dividends-Continued Money amounts economically less-developed countries FILED IN SUPPORT Foreign Income foreign tax credit foreign taxes deemed Foreign taxes paid FORM 1118 FILED France Includes Andorra geographic classifications combinations including gross-up Income and taxes income tax Japan includes Okinawa Netherlands Antilles Number Oceania Okinawa and Ryukyu overall limitation Total paid or accrued per-country limitation Returns Puerto Rico related foreign corporations Republic of includes RETURNS WITH FORM Returns with overall Returns with per-country Ryukyu Islands Schedule Second-tier foreign corporations selected country Selected major industry SUPPORT OF FOREIGN Table 6.-Total Assets TAX CREDIT CLAIMED taxes deemed paid taxes from specific Taxes Were Paid thousands of dollars TOTAL ASSETS U. S. Possessions U.S. corporation United Kingdom Venezuela West Germany Western Hemisphere
Popular passages
Page 131 - The common parent corporation owns directly stock possessing at least 80 percent of the voting power of all classes of stock and at least 80 percent of each class of the nonvoting stock of at least one of the other includible corporations. As used in this subsection, the term "stock" does not include nonvoting stock which is limited and preferred as to dividends.
Page 141 - Algeria, Ecuador, Gabon, Indonesia, Iran, Iraq, Kuwait, Libya, Nigeria, Qatar, Saudi Arabia, United Arab Emirates, and Venezuela.
Page 127 - Indies, and which satisfies the following conditions: (1) if 95 percent or more of the gross income for the 3-year period immediately preceding the close of the taxable year (or for...
Page 134 - ... effectively connected with the conduct of a US trade or business and does not have an office or place of business, or fiscal or paying agent, in the United States.
Page 143 - The net income shall first be computed by deducting from such gross income the expenses, losses, and other deductions properly apportioned or allocated thereto and a ratable part of any expenses, losses, or other deductions which can not definitely be allocated to some item or class of gross income.
Page 134 - The bill makes the foreign tax credit available to shareholders of a DISC (or former DISC) for any foreign income taxes paid by the corporation with respect to certain distributions (whether deemed or actual). This is accomplished by providing that dividends from a DISC (or former DISC) are to be treated as dividends from a foreign corporation to the extent the dividends are treated as from sources without the United States. An amendment to the source rules (adding sec.
Page 142 - Industrial divisions and groups were used as a basis for classifying tax return data according to the principal business activity of the corporation. Returns were classified in that industry which accounted for the largest portion of business receipts...
Page 141 - ... would have paid income tax to country Z in. an amount effectively equal to 30 percent of the income (after allocable deductions other than income or similar taxes) derived from the purchase and sale transaction. Therefore, with respect to this item of income, organization of B Corporation in country Y did not have the effect of substantially reducing income or similar taxes (26 percent being less than 90 percent of 30 percent but not being as much as 5 percentage points less than 30 percent),...
Page 142 - However, no controlled foreign corporation may qualify as an export trade corporation for any taxable year beginning after October 31, 1971, unless it qualified as an export trade corporation for any taxable year beginning before such date.
Page 1 - deemed paid" foreign tax credit to a domestic corporation, owning 10 percent or more of the voting stock of a foreign corporation...