TAX 9869 Lecture Notes - Lecture 28: Income Tax, Withholding Tax, Foreign Tax Credit

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17 Jul 2020
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Interest expense: is allocated to us source income and foreign source income no matter what: money is fungible and you can do whatever you want with your , could have had of services in japan and paid. Japanese tax but bc us company has interest expense it may be allocated against that , causing it to be (0) or (-) in foreign source basket. In this situation, tp may say i cant get credit anyway might as well take deduction: another reason, might take deduction in lieu of credit: Not an income tax (on test), therefore, cannot. Take as a credit: you should take it as a deduction, has to be an income tax, real property tax paid in foreign country, not credit, can be taken as a deduction. If you want to shift in a group who pays tax, can"t take credit because not your tax liability: you have to be the technical tp, mandatory/compulsory/required by foreign gov.

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