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- Title
The Foreign Branch Basket.
- Authors
Lokken, Lawrence
- Abstract
The article focuses on foreign branch income basket which revisited the separate limitation rules of Section 904(d) of the U.S. Internal Revenue Code (IRC). It mentions "Foreign branch income" is business profits of a U.S. person, other than passive category income, that are attributable to qualified business units (QBUs) of the taxpayer located in foreign countries. It also mentions passive and general foreign tax credit separate limitation categories is intended to prevent cross-crediting.
- Subjects
TAXATION of foreign income; UNITED States. Internal Revenue Code; CORPORATE profits; QUALIFIED business unit; FOREIGN exchange accounting; FOREIGN tax credit
- Publication
International Tax Journal, 2020, Vol 46, Issue 6, p13
- ISSN
0097-7314
- Publication type
Article