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Published in:
2016 | OriginalPaper | Chapter
13. The US Foreign Tax Credit Regime
Author : Felix I. Lessambo
Published in: International Aspects of the US Taxation System
Publisher: Palgrave Macmillan US
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Abstract
This chapter explains how US foreign tax credit aims to reduce the double tax burden that would otherwise arise when foreign source income is taxed by both the United States and the foreign country from which the income is derived. It goes on to analyze the complexities of the direct foreign tax credit, the indirect foreign tax credit, and the limitations imposed under Internal Revenue Code Section 904, foreign tax credit limitations, redeterminations, and generation.