Explanation of Proposed Income Tax Treaty (And Proposed Protocol) Between the United States And the Kingdom of Spain : Scheduled for a Hearing Before the Committee On Foreign Relations, United States Senate, On June 14, 1990 Jcs-17-90

Cover Explanation of Proposed Income Tax Treaty (And Proposed Protocol) Between the United States And the Kingdom of Spain : Scheduled for a Hearing Before the Committee On Foreign Relations, United States Senate, On June 14, 1990 Jcs-17-90
Explanation of Proposed Income Tax Treaty (And Proposed Protocol) Between the United States And the Kingdom of Spain : Scheduled for a Hearing Before the Committee On Foreign Relations, United States Senate, On June 14, 1990 Jcs-17-90
United States. Congress. Joint Committee On Taxation
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These rules apply to 50-percent-or-more U.S.-owned foreign corporations only.
In order to prevent a similar technique from being used to average foreign taxes among the separate limitation categories, the 1986 Act provided look-through rules for the characterization of inclu- sions and income items received from a controlled foreign corpora- tion.
Prior to the 1986 Act, a U.S. taxpayer with substantial economic income for a taxable year potentially could avoid all U.S. tax liabil- ity for such
...year so long as it had sufficient foreign tax credits and no domestic income (whether or not the taxpayer had economic income from domestic operations). In order to mandate at least a nominal tax contribution from all U.S. taxpayers with substantial economic income, the 1986 Act proved that foreign tax credits cannot exceed 90 percent of the pre-foreign tax credit tentative minimum tax (determined without regard to the net operating loss deduction). However, as amended by the Omnibus Budget Reconcil- iation Act of 1989, no such limitation is imposed on a corporation if more than 50 percent of its stock is owned by U.S.

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