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U.S. businesses overseas income tax credit system draw

Author: HuMinHua
Tutor: LanLan
School: China University of Political Science
Course: International Law
Keywords: Corporate income abroad Legal system of tax credits Limit of tax credit
CLC: F812.42
Type: Master's thesis
Year: 2011
Downloads: 238
Quote: 0
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Abstract


Arrangements through offshore income tax credit system to create a fair competitive environment for the country's multinational enterprises, while safeguarding the interests of the domestic taxes, is an inevitable choice for the world to deal with economic globalization. The United States is the world's first implementation of corporate foreign income tax credit and to reduce international double taxation country after nearly a century of development, the formation of a capital-export neutrality principle, fully consider incentives for overseas investment, both domestic The tax benefits of foreign income tax credit system, the legislative technique, operability, and has high reference value. Based on the tax payable on the third chapter of the \Bureau jointly issued a \offshore income tax credit Operations Guide, to further explain the operation of enterprises' overseas income tax credit. So far, China's new corporate overseas income tax credit system is basically formed. In this paper, through the detailed study of American enterprises' overseas income tax credit system, contrast combing our newly issued credit policy, analysis of the different system of China and the United States, to sum up the experience of the United States are available at our reference, and to improve and optimize our specific recommendations for enterprises' overseas income tax credit system. This paper is divided into four parts: The first part describes the history and development of the basic concepts of the enterprises' overseas income tax credit system, economic functions, as well as Sino-US credit system. The second part of the main line to the credit calculation process detailed interpretation of U.S. businesses overseas income tax credit system, and the analysis and evaluation of. The third part of the comparative analysis of the different points of the Sino-US regime, the credit method, the indirect credit applicable restrictions range of foreign tax credits, to postpone the tax rules, inside and outside the gain or loss complementary rules, overrun credits carry-over of the six comparison draw, summed up China's enterprises overseas income tax credit system improvements. The fourth part of the third part of the analysis results, combined with China's actual situation, put forward concrete proposals to improve and optimize our enterprises' overseas income tax credit system: on the one hand, it is recommended that as soon as the current system \Free limit changed to \On the other hand, to strengthen collaboration between government departments, the ability to continuously improve the anti-avoidance and consider to increase indirect credits layers to expand the range of complementary inside and outside the resulting gain or loss when conditions are ripe.

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CLC: > Economic > Fiscal, monetary > Finance, the state's financial > China's financial > Financial income and expenditure > Tax
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