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US Foreign Tax Credit limitation rules

Published on 01 Apr 09 by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE

Whilst most of us would not need to know how to perform the credit limitation calculation or ‘deemed paid’ calculation, many of us deal with the US in respect of their ownership of an Australian subsidiary or group. In this regard, it is important to understand the language and, more importantly, understand conceptually the key drivers for when and why dividends are sought to be repatriated by the US.

Author profile:

Neil Pereira CTA
Neil is a Principal of Corporate and International Tax with Deloitte Touche Tohmatsu Ltd. Current at 01 June 2010 Click here to expand/collapse more articles by Neil PEREIRA.
 
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