This Note will examine the United States tax treatment of foreign source income, under sections 911 and 913 of the Internal Revenue Code, to determine the effectiveness of either or both provisions with respect to the individual taxpayer and United States government objectives
tentative U.S. income tax of $107.9 billion by more than $26 billion by using the foreign tax credit...
This Note begins with commentary on the United States’ former worldwide system of taxation. This sys...
This article is a detailed study of the taxation by the United States of foreign base company servi...
The United States, for over three-quarters of a century, has maintained a foreign trade ...
The United States has the power to tax the income of its citizens and domestic corporations even tho...
The Economic Recovery Tax Act of 1981 made major revisions in the taxation of foreign earned income....
The Economic Recovery Tax Act of 1981 (ERTA) contains significant provisions liberalizing the taxati...
Over the last five years for which data are available, the number of foreign corporations showing ne...
This Article discusses Section 911 of the Internal Revenue Code, also known as the Foreign Earned In...
Internal Revenue Code Sections 861-864 determine the source of income and Sections 861(a) and 862(a)...
One possible method of reducing United States income tax liability is to expatriate, or renounce Uni...
Foreign taxpayers have long been a thorn in the side of Congress. Not only is the proper incidence o...
The United States, unlike many sovereignties, has exercised worldwide income tax jurisdiction over i...
The Domestic International Sales Corporation (hereinafter DISC) provisions were introduced into the ...
Section 904(f) prevents the taxpayers from enjoying the double benefit of deducting foreign source l...
tentative U.S. income tax of $107.9 billion by more than $26 billion by using the foreign tax credit...
This Note begins with commentary on the United States’ former worldwide system of taxation. This sys...
This article is a detailed study of the taxation by the United States of foreign base company servi...
The United States, for over three-quarters of a century, has maintained a foreign trade ...
The United States has the power to tax the income of its citizens and domestic corporations even tho...
The Economic Recovery Tax Act of 1981 made major revisions in the taxation of foreign earned income....
The Economic Recovery Tax Act of 1981 (ERTA) contains significant provisions liberalizing the taxati...
Over the last five years for which data are available, the number of foreign corporations showing ne...
This Article discusses Section 911 of the Internal Revenue Code, also known as the Foreign Earned In...
Internal Revenue Code Sections 861-864 determine the source of income and Sections 861(a) and 862(a)...
One possible method of reducing United States income tax liability is to expatriate, or renounce Uni...
Foreign taxpayers have long been a thorn in the side of Congress. Not only is the proper incidence o...
The United States, unlike many sovereignties, has exercised worldwide income tax jurisdiction over i...
The Domestic International Sales Corporation (hereinafter DISC) provisions were introduced into the ...
Section 904(f) prevents the taxpayers from enjoying the double benefit of deducting foreign source l...
tentative U.S. income tax of $107.9 billion by more than $26 billion by using the foreign tax credit...
This Note begins with commentary on the United States’ former worldwide system of taxation. This sys...
This article is a detailed study of the taxation by the United States of foreign base company servi...