Foreign Tax Credit for Corporations

Paper Summary:

This paper examines the issue of foreign tax credit for corporations under IRC section 901(b)(1). The paper first explains foreign direct investment in order that we may understand the relevant issues. The paper then gets into the specifics regarding tax credits and issues where these foreign investment companies are concerned.

Outline:
Chapter One - Introduction
Chapter Two - Review of Case and Ruling Issues
Chapter Three - Methodology
Chapter Four - Case and Ruling Analysis
Chapter Five - Summary, Conclusions, and Recommendations

From the Paper:

"The first limitation that is important to note is that there is so little information about the case study subject in question - the foreign tax credit. While there is indeed some information, much of it comes from laws and rulings as opposed to studies and research articles. With that in mind it is important to note where the information that is being collected for the study of this issue is coming from. There is no reason not to use the information that is provided by others, but making sure that one is aware of where it comes from and what potential consequences that could have is of utmost importance when it comes to looking at the limitations that can be found in research. Making sure that the most accurate data available is used is significant and when something cannot be verified it should be pointed out in the study that it cannot be verified so that there is no further confusion as to whether that piece of information is legitimate or not for the study."

Sample of Sources Used:

• Amoco Corporation and affiliated corporations vs. Commissioner of Internal Revenue. (1998). 138 F.3d 1139; 1998 U.S. App. LEXIS 4409; 98-1 U.S. Tax Cas. (CCH) P50,250; 81 A.F.T.R.2d (RIA) 998; 71 T.C.M. (CCH) 2613; T.C. Memo 1996-159; T.C.M. (RIA) 96159
• AMP Incorporated and consolidated subsidiaries vs. the United States. (1997). 40 Fed. Cl. 172; 1997 U.S. Claims LEXIS 304; 98-1 U.S. Tax Cas. (CCH) P50,137; 81 A.F.T.R.2d (RIA) 351
• The Badger Company, Inc. vs. Commissioner. (1967). T.C. Memo 1967-178; 1967 Tax Ct. Memo LEXIS 83; 26 T.C.M. (CCH) 869; T.C.M. (RIA) 67178
• Bankers Trust New York Corporation and consolidated subsidiaries vs. United States. (2000). 225 F.3d 1368; 2000 U.S. App. LEXIS 23503; 2000-2 U.S. Tax Cas. (CCH) P50,739; 86 A.F.T.R.2d (RIA) 6140
• Bank of America national trust and savings association, A national banking association, vs the United States. (1972). 198 Ct. Cl. 263; 459 F.2d 513; 1972 U.S. Ct. Cl. LEXIS 181; 72-1 U.S. Tax Cas. (CCH) P9418; 29 A.F.T.R.2d (RIA) 1172

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• Persuasive Essay # 112249 : "Earned Income Tax Credit"
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• Research Paper # 50487 : "Global Custody"

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