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Form 05 904

Form 05 904

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Instructions and help about Form 05 904

we will start the foreign tax credit limitation now obviously the starting point is always why is it there why do we have a foreign tax credit limitation and the short and simple answer is that the u.s and virtually every other country that has a foreign tax credit mechanism they want to protect their domestic tax base they want to protect their domestic tax base so if if i have a just as again as a simple example if i have a u.s corporation and it has a branch in a high tax place let's say germany i'm not sure whether germany today is so high tax let's uh let's make it japan which is uh still still higher tax although there has been rumblings within the japanese tax community about the government reducing reducing rates there quite a bit but at least presently in japan if a u.s company has a branch there and earns income it'll be taxed give or take a little bit at around 41 percent and of course we have a 35 percent rate in the united states now let's assume that this u.s company has

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