Читать книгу International Taxation - Adnan Islam - Страница 7

 Exporting U.S. products to foreign countries

 Exporting or performing services to foreign persons outside the United States

 Foreign branch of a U.S. business — Section 987Section 987 may apply when the U.S. taxpayer operates in a branch form (such as a check-the-box foreign disregarded entity or a foreign partnership) and such branch is a QBU with a functional currency different than that of its owner.

 New benefits and tax provisions available only to C corporations under the TCJA

 Subpart F income from CFCs

 global intangible low-taxed income (GILTI) from CFCs

 Dividends Received Deduction (DRD) or Participation Exemption applicable for C corps that own at least 10% of a foreign corporation — Section 245A

 Investment in U.S. property by a CFC — Section 956

 Section 863(b) sourcing rules modifications

 Foreign tax credits (FTC)Direct foreign tax credit, Section 901Indirect or deemed-paid credit, Section 902 (repealed by the TCJA)Allowable credit calculated on Forms 1118 (corporate) or 1116 (individual)

 Limitation on FTC, Section 904

 U.S. shareholders of PFICs

 Limits on interest expense for U.S. businesses (that is, 30% of adjusted taxable income [ATI])