Topic: Foreign tax issues

Description: (Yao)

Taxation of non-resident

How the US taxes foreign-source income?

What is the challenge?

1. foreign income tax in the local country where rhe income is earned

2. withholding taxes that may apply upon the pmt of a div. from the foreign sub to the US parent

3. US income tax on foreign sourced income accumulated in a foreign sub when the foreign sourced income is repatriated to the US

Discussion of issues:

Foreign tax credit
Organizational forms: Tax consequences: (a foreign branch vs. a foreign partnership vs. a foreign sub)
Allowance valuation
Anti-deferral rules

Requirements:

1. first 1/3: description of tax issue or problem & the applicable tax laws that apply; second 2/3 of paper: discussion, analysis, tax planning, data analysis, problem solving portion of paper. Attach complete bibliography of works consulted & tax citations

2. double spaced with end notes & pagination

3. papers are penalized for short length, wide margins & papers that are descriptive or historical in nature only and lack substantial content and analysis.

Please answer the foreign tax credit in the discussion part. As for foreign tax credit, please do the discussion, analysis, tax planning, data analysis, problem solving portion of paper. Attach complete bibliography of works consulted & tax citations.