1118 and 1116

samedi 25 juillet 2015

Hello!
Please chec the below case if you've known about the answer.
Here is the case:A, is a china citizen, US green card holder.A is 10% US shareholder of a CFC in china. A had a qualified diviend 3M usd from CFC. A paid 5% dividend income tax in China. US federal tax rate is 23.8%, 18.8% difference. The CFC paid 25% income tax for the CFC net profit in china. A decided using 1118 form to offset his us tax liab.

Questions:1. His us income tax rate will be completed change into corp tax rate or just for the dividend part?
2.What about the 5% dividend foreign income tax paid(1116)? It can be used in the same year as 1116 or as SchA tax deduction or only can be carried over or wasted for ever?

Thanks!


1118 and 1116

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