TITLE

Cross-Border Business Combinations

AUTHOR(S)
Jackman, Patrick; Tretiak, Philip
PUB. DATE
September 2010
SOURCE
International Tax Journal;Sep2010, Vol. 36 Issue 5, p5
SOURCE TYPE
Academic Journal
DOC. TYPE
Article
ABSTRACT
The article focuses on the enactment of new Code Sec. 901(m) by the U.S. Education Jobs and Medicaid Assistance Act of 2010 for dealing with the foreign tax credit (FTC) for foreign income tax in connection with a covered asset acquisition. It discusses the transactions under the covered asset acquisition, the history of Code Sec. 338, the foreign tax credit that provides relief from double taxation, and the implications of Code Sec. 901(m) for U.S. buyers who want to acquire a foreign target.
ACCESSION #
53697821

 

Related Articles

  • DESIGNING A U.S. EXEMPTION SYSTEM FOR FOREIGN INCOME WHEN THE TREASURY IS EMPTY. Fleming Jr., J. Clifton; Peroni, Robert J.; Shay, Stephen E. // Florida Tax Review;2012, Vol. 13 Issue 8, p397 

    The article reports the need of a territorial or exemption system in the U.S. under which foreign-source active business income earned by U.S. resident corporations would become substantially free of U.S. income tax. Topics discussed include the need of reform of the U.S. international tax...

  • Foreign Tax Credits. Riedy, James A. // International Tax Journal;Sep2010, Vol. 36 Issue 5, p11 

    The article focuses on the consequences of foreign tax credit (FTC) in the U.S. in cases where tax attributes of foreign target companies are retained. It discusses the foreign tax credit for the foreign income tax paid in connection with a covered asset acquisition under the New Code Sec....

  • President's Economic Recovery Advisory Board: Suggested Considerations in Fundamental Reform of the United States Tax Treatment of Income from Cross Border Trade and Investment. Dilworth, Robert H. // Northwestern Journal of International Law & Business;Summer2010, Vol. 30 Issue 3, p551 

    The article offers recommendations on the tax reform methodology in the U.S. in response to the President's Economic Recovery Advisory Board (PERAB) of President Barack Obama. It suggests that the tax reform should not be carried out, should there be no thorough understanding of the problem of...

  • Relief from Double Taxation: The Treatment of Foreign Tax Paid for Individuals at the State Level. Sherman, W. Richard; Brinker Jr., Thomas M. // National Public Accountant;Dec/Jan2003, p34 

    Discusses the treatment of foreign tax paid for individuals at the state level in the U.S. Occurrence of double taxation; Deductions for foreign taxes; Credit for foreign taxes; Tax exemptions of foreign income. INSET: Foreign Income Taxes: Treatment at State Level.

  • WHEN USCORP GOES GLOBAL: TAX RULES AND POLICY CONSIDERATIONS. Serocki, James // International Journal of Business Research;2007, Vol. 7 Issue 1, p170 

    This article provides an overview of the tax rules and underlying policy considerations regarding the international tax system for a U.S. corporation (USCORP) commencing foreign operations. A USCORP must deal with many new tax laws and regulations, layered upon domestic operation tax rules, when...

  • Corporate Foreign Tax Credit, 1999. Raub, Brian // Statistics of Income (SOI) Bulletin;Fall2003, Vol. 23 Issue 2, p205 

    Provides information on several U.S. corporations that claimed foreign tax credits in 1999. Leading sources of foreign-source taxable income for U.S. corporations claiming a foreign tax credit; Statutory income categories; Types of foreign-source gross income.

  • Individual Foreign-Earned Income and Foreign Tax Credit, 2006. Hollenbeck, Scott; Kahr, Maureen Keenan // Statistics of Income (SOI) Bulletin;Spring2009, Vol. 28 Issue 4, p54 

    The article offers information on the tax returns of foreign-earned income and the foreign tax credit in the U.S. It notes of a 13.6 increase in the filed tax returns by the tax payers from 2001 to 2006. It mentions that 72.9 percent of reported total foreign-earned income is comprised by...

  • A Note From the Editor-in-Chief. Yoder, Lowell D. // International Tax Journal;Jul/Aug2011, Vol. 37 Issue 4, p3 

    The article focuses on the impact of the taxation rule Code Section 901 (m) for certain foreign acquisitions. It says that the rule applies to the so-called covered asset acquisitions treated for U.S. purposes and does not lead to U.S. tax consequences to the buyer. It adds that stock...

  • OPTIMAL DECISION BETWEEN FOREIGN TAX CREDIT AND FOREIGN EARNED INCOME EXCLUSION. Yang, James G. S.; Jeffers, Agatha E. // International Journal of Business Research;2007, Vol. 7 Issue 1, p111 

    This paper explains that a U.S. citizen working abroad can choose either the foreign tax credit or the foreign earned income exclusion when calculating his U.S. income tax liability. By using the former, the foreign tax paid can be used as a credit against the U.S. tax to the extent of the U.S....

Share

Read the Article

Courtesy of VIRGINIA BEACH PUBLIC LIBRARY AND SYSTEM

Sorry, but this item is not currently available from your library.

Try another library?
Sign out of this library

Other Topics