Article

A Projection of the Maximum U.S. Revenue Loss From Foreign Tax Credit for VAT

March 2007

Authors:

My presentation to the VAT Committee at the January 2007 meeting of the ABA Section on Taxation included a projection of the maximum revenue loss if foreign tax credit for value-added taxes were adopted in the U.S. The discussion following my presentation included several suggestions for improving the projection, and this short Article incorporates some of those suggestions and documents the data on which I relied.

ResearchGate has not been able to resolve any citations for this publication.

ResearchGate has not been able to resolve any references for this publication.

Article

911 v. 913: HOW THE FLAWS OF THE FOREIGN EARNED INCOME EXCLUSION COULD BE CORRECTED BY A MODIFIED VE...

January 1970

Ryan M Borgmann

This Article addresses the use of earned income as basis for allowing a tax benefit to individuals who live and work abroad. With the exception of a short period of time in the late 1970’s and early 1980’s, earned income has been used to provide a tax benefit for United States citizens and residents living and working abroad. The reasoning for this tax benefit has always been to provide ... [Show full abstract] assistance for the higher cost of living and higher tax rate of living in a foreign country, yet the tax benefit has been available to every individual living abroad, independent of whether they are need of tax assistance due to higher expenses. This Article provides an analysis of the history of the foreign earned income exclusion and the flaws with using an individual’s income as the basis to provide a tax benefit. After identifying the problems with the use of earned income, the Article provides a solution that utilizes Section 913 as its foundation; the Tax Code Section that was in place in the aforementioned late 1970’s and early 1980’s. The Article concludes that using a modified version of Section 913 would provide the tax benefit to those individuals to whom the foreign earned income exclusion was designed to assist, while solving some of the concerns posed when Section 913 was repealed in 1981.

Physical person income tax

January 2001

Yu.M. Chebotar

The second part of Tax Code of Russian Federation came into force effect on January 1, 2001. New order of taxation was determined. New order of physical person income was also established. In the past, the order was determined by instruction of State Tax Service of Russian Federation No. 35 of June 29, 1995, Federal Law No. 27-F3 of February 2, 1999, and other documents. New order of taxation was ... [Show full abstract] also determined for foreigner income taxation. Privileges of physical persons were described. Order of physical person income tax payment was determined. State monitoring of taxation was shown. Time of physical person tax payment was noted.

Australian Dividend Withholding Tax

January 2008 · Revenue Law Journal

Glen A Barton

Subsection 128B(4) of the Income Tax Assessment Act 1936 (Cth) imposes income tax on Australian dividends that are subject to section 128B. The application of section 128B to a particular corporate distribution will depend, in broad terms, on the nature of the distribution and its source, the manner or capacity in which the recipient derives it and the recipient’s residence and tax status. The ... [Show full abstract] relevant legislative provisions are spread across the Income Tax Assessment Acts of 1936 and 1997, Australia’s Double Tax Agreements, the Taxation Administration Act and the Income Tax (Dividends, Interest and Royalties Withholding Tax) Act 1974. They include provisions that define, for Australian income tax purposes, concepts such as ‘dividend’, ‘non – share dividend’, ‘franked dividend’, ‘demerger dividend’, ‘dividend attributable to a permanent establishment’ and dividends that are ‘conduit foreign income’. Certain entities are obliged, by provisions in Subdivision 12 – F in Schedule 1 to the Taxation Administration Act, to withhold income tax payable under subsection 128B(4) from the effected dividends they pay or receive. A taxpayer’s Australian assessable or exempt income does not include Australian dividends upon which subsection 128B(4) withholding tax is payable and so the taxpayer is not obliged to lodge an Australian tax return on account of them.

View full-text

Article

Instilling Subpart F with Horizontal Equity as Applicable to Individual U.S. Shareholders

November 2019 · The ATA Journal of Legal Tax Research

Irwin J. (Jay) Katz

Subpart F of the Internal Revenue Code is a body of anti-abuse provisions designed to prevent U.S. shareholders from avoiding tax on the earnings (Subpart F income) generated by foreign corporations they control. Overall, its provisions lack the tax principle of horizontal equity based on tax neutrality. This article will expose the lack of horizontal equity, as applied to individual (not ... [Show full abstract] corporate) U.S, shareholders by being both over-inclusive and under-inclusive. It is over-inclusive in imposing punitive tax consequences when tax avoidance is unachievable including the taxation of GILTI, a new type of Subpart F income. It is underinclusive because tax avoidance is achievable by taking advantage of certain loopholes in Subpart F. Using I.R.C. {section sign} 469 (that successfully eliminated tax shelters) as a model, this article recommends revisions to relevant Subpart F provisions that will eliminate tax avoidance without punitive tax consequences and also foreclose potential tax avoidance opportunities.

Section 10(1)(o)(ii): Introduction to Policy Changes and Effects of Interactions of Varying Levels o...

October 2020

Brendon Smith

As per the Taxation Laws Amendment Act of 2018 (National Treasury, 2017), proposed changes to the taxation of foreign source income such that foreign source remuneration, when meeting specific requirements, will no longer be fully exempted but rather only the initial R1 million per annum being exempted, with the excess included in South African taxable income. There exists a need to explain how ... [Show full abstract] this change will affect taxpayers in terms of the application to mixed-source income as well as to examine if the amendment is equitable given varying levels of mixed-source taxable income. This is examined through a numerical examination of section 10(1)(o)(ii) and the interaction and effects on the double tax relief provided by section 6quat.

View full-text

Article

Full-text available

FOREIGN INCOME – PROBLEMS OF DOUBLE TAXATION

November 2018 · International Journal of Innovative Technologies in Economy

The article highlights implications of foreign income taxation of Ukrainian tax residents. Based on the effective Tax Conventions on Income and on Capital, individuals can claim a credit of tax paid abroad against their Ukrainian tax due. However, the claim must be supported by a specific document prescribed by Ukrainian legislation. In practice, the obtaining of the proper document from foreign ... [Show full abstract] tax authorities may be impossible for taxpayers, bringing the double taxation of personal income. Thus, the options of improvement of tax credit mechanism and unification of official confirmation of tax base and tax payment were proposed.

View full-text

A Projection of the Maximum U.S. Revenue Loss From Foreign Tax Credit for VAT

Abstract

No full-text available

Recommended publications

911 v. 913: HOW THE FLAWS OF THE FOREIGN EARNED INCOME EXCLUSION COULD BE CORRECTED BY A MODIFIED VE...

Physical person income tax

Australian Dividend Withholding Tax

Instilling Subpart F with Horizontal Equity as Applicable to Individual U.S. Shareholders

Section 10(1)(o)(ii): Introduction to Policy Changes and Effects of Interactions of Varying Levels o...

FOREIGN INCOME – PROBLEMS OF DOUBLE TAXATION