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The U.S. Taxation of Multinational Transactions


Upon completing this chapter, you should be able to:

LO 24-1Understand the basic U.S. framework for taxing multinational transactions and the role of the foreign tax credit limitation.

LO 24-2Apply the U.S. source rules for common items of gross income and deductions.

LO 24-3Recall the role of income tax treaties in international tax planning.

LO 24-4Identify creditable foreign taxes and compute the foreign tax credit limitation.

LO 24-5Distinguish between the different forms of doing business outside the United States and list their advantages and disadvantages.

LO 24-6Comprehend the basic U.S. anti-deferral tax regime and identify common sources of subpart F income.











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