Defining Foreign Source Income (FSI)
Where a system imposes limits on FTC based in some manner on foreign source income (FSI), the system generally provides rules for determining whether income is foreign or domestic source. These rules may be relatively simple or quite complex. (For simplicity of wording below, the phrase "sourced to" specifies in the target the place (foreign or domestic) constituting the source of the income in the object for computing FTC limitation.) The following discussion explains U.S. and Canadian rules and certain other variations on one of these rules to illustrate the manners in which systems define FSI and the potential level of complexity. These rules vary highly by country.
Read more about this topic: Foreign Tax Credit
Famous quotes containing the words defining, foreign, source and/or income:
“The U.S. is becoming an increasingly fatherless society. A generation ago, an American child could reasonably expect to grow up with his or her father. Today an American child can reasonably expect not to. Fatherlessness is now approaching a rough parity with fatherhood as a defining feature of American childhood.”
—David Blankenhorn (20th century)
“Most of our occupations are low comedy.... We must play our part duly, but as the part of a borrowed character. Of the mask and appearance we must not make a real essence, nor of what is foreign what is our very own.”
—Michel de Montaigne (1533–1592)
“We are threatened with suffering from three directions: from our own body, which is doomed to decay and dissolution and which cannot even do without pain and anxiety as warning signals; from the external world, which may rage against us with overwhelming and merciless forces of destruction; and finally from our relations to other men. The suffering which comes from this last source is perhaps more painful than any other.”
—Sigmund Freud (1856–1939)
“Happy are those who find wisdom, and those who get understanding, for her income is better than silver, and her revenue better than gold. She is more precious than jewels, and nothing you desire can compare with her. Long life is in her right hand; in her left hand are riches and honor. Her ways are ways of pleasantness, and all her paths are peace. She is a tree of life to those who lay hold of her; those who hold her fast are called happy.”
—Bible: Hebrew, Proverbs 3:13-18.