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 industrial world would be a more peaceful place if workers were called in as collaborators in the process of establishing standards and defining shop practices, matters which surely affect their interests and well-being fully as much as they affect those of employers and consumers.”
—Mary Barnett Gilson (1877–?)
“I have been told lately that Fuseli was travelling by coach and a gentleman opposite him said: “I understand, Mr. Fuseli, that you are a painter; it may interest you to know that I have a daughter who paints on velvet.”
Fuseli rose instantly and said in a strong foreign accent, “Let me get out.””
—Samuel Butler (1835–1902)
“If all else perished, and he remained, I should still continue to be; and if all else remained, and he were annihilated, the universe would turn to a mighty stranger. I should not seem a part of it.... My love for Heathcliff resembles the eternal rocks beneath—a source of little visible delight, but necessary. Nelly, I am Heathcliff—he’s always, always in my mind—not as a pleasure, any more than I am always a pleasure to myself—but as my own being.”
—Emily Brontë (1818–1848)
“We commonly say that the rich man can speak the truth, can afford honesty, can afford independence of opinion and action;—and that is the theory of nobility. But it is the rich man in a true sense, that is to say, not the man of large income and large expenditure, but solely the man whose outlay is less than his income and is steadily kept so.”
—Ralph Waldo Emerson (1803–1882)