PUNCTUATION

1. The amounts paid are personal expenses thus they are not deductible living

per §262(a) which specifically prohibits a deduction for personal or family expenses. 2. However and if these assumptions are incorrect therefore includable in Bell Riddell (TCM, 1972)

the payment will be alimony

s gross income. the taxpayer argued that his and

3. In a similar case

monthly restitution of stolen funds thus not taxable.

should be reclassified as a loan

4. One element is a tax economic benefit. 5. To be creditable

and the other is a payment

in exchange

for the

the foreign levy must be an income tax in the “U.S. sense it s not creditable under

6. Since the foreign levy is unlikely to reach “net gain Section 901. 7. If the taxes do not qualify for the foreign tax credit a §164 deduction.

they should qualify

as

8. The income tax paid to Sweden is qualified under these standards it is allowed as a foreign tax credit. 9. A value-added tax is not imposed on foreign source income. Thus considered an income tax in the U.S. sense tax credit.

therefore

it is not

and it does not qualify for the foreign

Contributions claiming the deduction results in a to the tax-exempt organization are deductible. §1. Since double tax benefits are not allowed dollar-for-dollar reduction in the credit. A value-added tax (VAT) is based on the value of the goods or services thus it is deductible. and it is not allowable . 11. Rev.10. 56-635 states that a turnover tax resembling a sales tax is not a tax in lieu of the general income tax within the meaning of §903 as a credit.901-2(a)(2)(i) specific economic benefit when a compulsory payment is exchanged for a the levy is considered to have two distinct elements. Rul. s rationale for allowing 13. Rev. 74-90 used the US-Germany treaty as it a foreign tax credit. 12. and 15. 14. Under Reg. Rul.

Rev. . Rul.15. 56-635 states that a turnover tax resembling a sales tax is not a tax in lieu of the general income tax within the meaning of §903 and it is not allowable as a credit.

Sign up to vote on this title
UsefulNot useful