A comprehensive U.S. legislation that repeals the Foreign Sales Corporation/Extraterritorial Income regime and enacts a variety of tax-related changes to boost domestic job creation.
A Controlled Foreign Company (CFC) is a foreign-based corporation that is controlled by residents of the home country, allowing individuals or companies to potentially shift profits and reduce their tax liabilities.
A Double Taxation Agreement (DTA) is an agreement between two countries aimed at preventing the same income from being taxed twice. These agreements offer various forms of double taxation relief to companies or individuals who are subject to tax in both countries.
The Foreign Tax Deduction allows individuals to deduct foreign income taxes paid or accrued from their U.S. income tax, or alternatively, apply the taxes as a credit against U.S. income tax liabilities.
The status of an individual who does not reside in a specific country for fiscal purposes, potentially affecting their tax obligations within that country.
In the UK Capital Gains Tax rules, an individual 'ordinarily resident' is subject to the tax even if they are not actually living within the UK. This status applies to various scenarios such as imprisonment abroad or taking a gap year.
Income that has been subject to taxation outside the jurisdiction of one's resident country's tax authorities. When the same income is subject to taxation in more than one country, relief for the double tax is given either under the provisions of the double taxation agreement with the country concerned or unilaterally.
Understanding the concept of a 'Permanent Establishment' (PE) is crucial for determining tax obligations and compliance in international business activities. The term is extensively used in international tax treaties to specify when and how business profits should be taxed.
A resident is an individual or company that is considered to be based in the UK for taxation purposes, determined by specific criteria set by HM Revenue and Customs (HMRC).
A tax exile is an individual who relocates to a country with more favorable tax conditions to avoid high taxation in their home country.
Tax treaties are agreements negotiated between two or more countries to avoid double taxation of income earned in one country by residents of another and to prevent tax evasion.
An agreement between two countries that specifies how income, profits, or gains are taxed to prevent double taxation and provide tax relief.
Transfer pricing involves setting prices for transactions between affiliated entities under common ownership, often used to allocate revenue and expenses among those entities to benefit from tax advantages.
Unilateral relief is a measure taken by the UK authorities to provide relief against double taxation for taxes paid in a country with which the UK does not have a double-taxation agreement.
