Foreign and domestic marketing tax credits as stimulants to economic activity and employment

Article Abstract:

A foreign and domestic marketing expense tax credit would provide firms with an incentive to expand production and increase employment. Tax credits for marketing would be more beneficial for companies with excess capacity than the existing investment tax credit because such firms would not be interested in additional capital expenditures. Surveys of California businesses in key industries indicates that a majority would expect that a marketing tax credit would lead to expansion and increased jobs.

Taxation, Economic aspects, Marketing, Tax credits, Investment tax credit

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Allocation and apportionment of expenses for the foreign tax credit

Article Abstract:

Taxpayers hoping to take advantage of the foreign tax credit need to be very familiar with the rules of apportionment and allocation of expenses not associated with foreign and domestic income. A factual relationship between sources of allocated deductions must be made and apportioned between statutory groups. State and local income taxes may be allocated and apportioned through the use of one of two safe harbor methods. The deductibility of stewardship and supportive expenses are also discussed.

International aspects, Accounting and auditing, Recognition of gain or loss (Taxation), Recognized gain or loss (Taxation), Foreign tax credit, Allocation (Taxation), Tax allocation

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Transfer of property to foreign entities under Section 367(a)(3)(C)

Article Abstract:

IRC 367(a)(3)(C) is designed to prevent the indefinite deferment of income taxes on transferred property through its branch loss recapture provisions. Previously, the loss of opening a foreign branch by a US taxpayer could be deducted and subsequent incorporation could prevent payment of taxes on gain until dividend distribution. Limitations on gains, transfers and rules to prevent this type of abuse are Congress' attempt to limit tax avoidance in this manner.

Foreign operations, Corporations, Transfer (Law)

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