Intercompany Royalties: Foreign Tax Credit Category

Yoder, Lowell D.
November 2011
International Tax Journal;Nov2011, Vol. 37 Issue 6, p3
Academic Journal
The article presents information on taxation on foreign source royalty income of Controlled foreign Corporations (CFC) by U.S. multinational parent companies. As stated, the U.S. tax on foreign source royalty income can be reduced if royalty income falls in the active category. It also discusses that royalties received by a U.S. parent company from CFC will be categorized in active basket if intangible property is not licensed to a third party.


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