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Form 8873 is attached to the taxpayers income tax return. Both corporate and non-corporate taxpayers who have qualifying transactions may now be required to file Form 8873. The exclusion reported on Form 8873 was created by the Foreign Sales Corporation (FSC) Repeal and Extraterritorial Income Exclusion Act of 2000. The new exclusion applies to ...
One form of income listed in the Code, that of "discharge of indebtedness" is not often considered income by lay persons. If, however, a taxpayer owes a debt to any other party, and that debt is forgiven without being fully repaid, the taxpayer must as a general rule declare the forgiven amount as income, and must pay tax on it. [6]
Federal income tax was first introduced under the Revenue Act of 1861 to help pay for the Civil War. It was renewed in later years and reformed in 1894 in the form of the Wilson-Gorman tariff. Legal challenges centered on whether the income tax then in force constituted a "direct tax". In the Springer v.
Should the taxpayer be involved in a dispute with a foreign tax administration regarding the covered transactions, they may seek relief by requesting that the U.S. competent authority initiate a mutual agreement proceeding. This assumes, of course, that there is an applicable income tax treaty in force with the foreign country. The APA Program
Generally, the amount of dividend is "grossed up" for the amount of available credit, before limitations, effectively charging the shareholder with home country tax for the income on a pre-tax basis. [56] The deemed paid credit mechanism may be applied up the chain of corporate distributions, and may be subject to ownership limitations. [57] [58]
Today, shareholders of a DISC continue to receive reduced income tax rates on qualifying income from exports of U.S.-made goods. A DISC is a U.S. corporation that has elected DISC status and meets certain other largely symbolic requirements. [1] A corporation so electing is not subject to U.S. Federal income tax. [2]
An advance tax ruling binds tax authorities to comply with the tax arrangements set out in the ruling. Advance tax rulings are common in numerous countries. The Luxembourg Leaks provide insight into the practice of advance tax rulings in Luxembourg used by corporations as a tool for devising strategies that help them avoid taxes. [1] [2]
A customs duty or due is the indirect tax levied on the import or export of goods in international trade. In economics a duty is also a kind of consumption tax. A duty levied on goods being imported is referred to as an 'import duty', and one levied on exports an 'export duty'.