LexisNexis® Legal Newsroom
Distinctions Between State and Federal Taxation of Foreign Source Income

By Suellen M. Wolfe, LL.M., CPA The federal Internal Revenue Code provides that foreign corporations are subject to U.S. income tax on certain foreign source income that is "effectively connected" with a U.S. trade or business. Jurisdiction to subject the foreign corporation to U.S. income...

Congress Considers Repeat of Tax Repatriation Holiday

Congress is looking at a House bill that would revive the dividends received deduction of IRC Section 965 and provide U.S. corporations with operations abroad a tax break on repatriated profits for 2011 or 2012. (See Lexis Tax Advisor -- Federal Code § 965(a) ). The bill was introduced by Representative...

Repatriation Tax Holidays and IRC Section 965

By Mary Riley * The debate over corporate tax reform has largely centered on lowering the corporate tax rate and, more radically, transitioning from a worldwide to a territorial system of international taxation. [Donald J. Marples and Jane G. Gravelle, CONG. RESEARCH SERVE, R40178, TAX CUTS ON REPATRIATION...

State Tax Essentials: Corporate Income Tax Computations

by Robert Desiderio * Although there is some measure of conformity with the federal corporate income tax base, every state's statute makes its measure of tax corporate income different from the federal base. Typically, there are additions and subtractions from the adopted federal starting point...