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For Foreign Tax Credit purposes, certain types of income are re-characterized (looked-through) based on the character of the income underlying the payment. [5] Dividends received from a 10% or more owned controlled foreign corporation (CFC) with respect to which the recipient is a U.S. shareholder (whether or not the controlling shareholder) are re-characterized based on the earnings and ...
Deferral of active income of controlled foreign corporations: 25.8 Reduced rates for first $10,000,000 of corporate taxable income: 23.7 Deduction for income attributable to domestic production activities: 19.8 Tax credit for low-income housing: 17.5 Exclusion of investment income on life insurance and annuity contracts: 12.8
Any foreign (i.e., non-U.S.) corporation meeting either the income test or the asset test is a PFIC with respect to each shareholder when the test is met. [4] PFIC status applies separately for each U.S. person owning shares, and also separately with respect to shares acquired at different times.
Qualified dividends are taxed at a different rate than your regular, earned income or income from interest payments. In and of themselves, regular dividends and qualified dividends are similar.
Items of income which (after considering deductions, etc., under U.S. concepts) were subject to foreign income tax in excess of 90% of the highest marginal U.S. tax rate for the type of shareholder; De minimis amounts of Subpart F income in absence of other Subpart F income in the period;
The maximum exclusion is $130,000 for tax year 2025 (future years indexed for inflation). [3] The amount of exclusion that a taxpayer is entitled to is equal to the lesser of foreign earned income for the year or the maximum exclusion, divided by the total number of days (365 or 366) in the year times the number of "qualifying days".
The dividends received deduction is limited with regard to the corporate shareholder's taxable income. Per §246(b) of the IRC, a corporation with the rights to a seventy percent dividends received deduction, can deduct the dividend amount only up to seventy percent of the corporation's taxable income.
The Foreign Sales Corporation (FSC) was created in 1984 as an alternative to the DISC. In 1984, partially in response to international pressure, U.S. law was amended to provide that a DISC and its shareholders could continue to defer tax on the DISC’s income, but only if the DISC shareholders paid interest on the deferred tax. [8]