What Is The Irs Voluntary Disclosure Amnesty: Difference between revisions
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Revision as of 12:39, 23 October 2024
A credit is allowed for foreign income taxes paid or accrued. The financial lending is limited for that part of U.S. tax due to foreign source income. It is far from refundable, but any excess credit can be carried to other years to reduce tax.
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Structured Entity Tax Credit - The internal revenue service is attacking an inventive scheme involving state conservation tax attributes. The strategy works by having people set up partnerships that invest in state conservation credits. The credits are eventually burnt up and a K-1 is distributed to the partners who then go ahead and take credits on the personal yield. The IRS is arguing that there isn't legitimate business purpose transfer pricing for that partnership, rendering it the strategy fraudulent.
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