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Rev proc 2018-17 Form: What You Should Know
Rev. Pro. 2018-17— (Sec. 301) Limits the liability of a person with respect to a failure to report foreign base company income. Limits the limitation on gross income of a corporation by the basis of dividends and interest paid or accrued by a subsidiary of the corporation. (Sec. 302) Revises the conditions under which a deferred foreign tax credit is allowed for tax paid or accrued from its first taxable year beginning after November 11, 1994, through the latter of (1) the last day of the calendar year in which such taxable year begins, and (2) December 31 if such credit is fully earned by the mayor on the day immediately preceding the date of payment (Sec. 303) Directs the Secretary to require certain taxpayer entities, which are subject to the AMT, to obtain a written statement from the United States with respect to any taxable year in which either (1) the sum of specified foreign base company income or income dividends is less than 200,000, or (2) the combined cost of property for all specified foreign base company income for taxable years beginning during a single taxable year is less than or equal to 200,000. (Sec. 304) Requires the Secretary, pursuant to regulations prescribed by the Secretary, to establish a threshold income level for tax on income of a corporation derived from specified foreign sources. (Sec. 305) Amends the Internal Revenue Code to exempt from the computation of tax under the Internal Revenue Code, a partnership interest equal to the partner's distributive share of profits accruing under a foreign subsidiary (a non-U.S. controlled foreign corporation). (Sec. 306) Revises the meaning of specified foreign earned income for purposes of the special rule for foreign corporations that are not U.S. corporations by extending the application of such income to certain non-U.S. controlled foreign corporations in which the partnership receives no income (and no capital gains), and by making certain related provisions of the Code applicable to such partnerships (Sec. 307) Allows for an election by a taxpayer to reduce or eliminate qualified joint and survivorship gain in a taxable year by the least of the following amounts: (1) the amount by which the taxpayer's adjusted gross income exceeds 200,000 (as adjusted for inflation under Sec.
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