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US Foreign Tax Credit limitation rules

Taxation in Australia | 1 Apr 09
 
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Published on 01 Apr 09 by "TAXATION IN AUSTRALIA" JOURNAL ARTICLE

Whilst most of us would not need to know how to perform the credit limitation calculation or ‘deemed paid’ calculation, many of us deal with the US in respect of their ownership of an Australian subsidiary or group. In this regard, it is important to understand the language and, more importantly, understand conceptually the key drivers for when and why dividends are sought to be repatriated by the US.

Author profile

Neil Pereira CTA
Neil is a Tax and Legal Partner with more than 20 years of international tax advisory and structuring experience for multinational clients across a range of industries. Neil’s extensive experience includes leading multidisciplinary teams on tax planning and due diligence for corporate reorganisations, legal entity reduction and consolidation of Australian operations for tax and broader business model and supply chain optimisation. Neil has advised clients on the Australian tax and legal implications of setting up business structures, share and business transfers, IP migration, foreign investment review board as well as regulatory and tax compliance for multinational groups. - Current at 25 July 2022
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