Observing the requirements in a consolidated manner

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the message that emerges is that the credit of (a) taxes on income and (b) withholdings that represent a replacement for taxation on income ( in leau of income taxes ) must bear similarity to the way the United  be based on a taxable event that represents an event of effective income realization, (2) use a methodology that recognizes gross income as starting point, (3) allow the deduction of expenses to arrive at a net income, (4) and respect the existence of the attribution link between the source of the income and the jurisdiction that exercises jurisdiction over the non-resident or the local subsidiary.

Note that the requirement for similarity to the American rule does not necessarily represent similarity to OECD standards. There are certain measures that, at some point, were targeted by the OECD in the context of efforts to contain base erosion, but that have not been EX Mobile Phone Numbers internalized by US legislation. An example is the so-called significant economic presence introduced by India and Nigeria, which appears as a component of a certain Beps action, but goes against the traditional concept of permanent establishment adopted by the United States.



As part of the new rule, the taxpayer himself must submit foreign taxes to the attribution test for the credit to be accepted. One of the main examples mentioned by the legislation is that of a controlled foreign entity (example, Entity A located in Country X) that receives a right to explore internationStates taxes the income of nonresidents. In other words, the rule of the jurisdiction of origin of the tax submitted for potential credit must, cumulatively: (1)l markets (exporting services to customers in Country.