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A foreign tax credit (FTC) is generally offered by income tax systems that tax residents on worldwide income, to mitigate the potential for double taxation. The credit may also be granted in those systems taxing residents on income that may have been taxed in another jurisdiction. The credit generally applies only to taxes of a nature similar to the tax being reduced by the credit (taxes based on income) and is often limited to the amount of tax attributable to foreign source income. The limitation may be computed by country, class of income, overall, and/or another manner. Most income tax systems therefore contain rules defining source of income (domestic, foreign, or by country) and timing of recognition of income, deductions, and taxes, as well as rules for associating deductions with income. For systems that separately tax business entities and their members, a deemed paid credit may be offered to entities receiving income (such as dividends) from other entities, with respect to taxes paid by the payor entities with respect to the income underlying the income recognized by the member. Systems with controlled foreign corporation rules may provide deemed paid credits with respect to deemed income inclusions under such rules. Some variations on the credit provide for a credit for hypothetical tax to encourage foreign investment (sometimes known as tax sparing). Detailed rules vary among taxation systems. Examples below are given for illustration purposes only and may not reflect the rules in a particular tax system. ==Credit for foreign income taxes== A reduction of tax (credit) is often provided in income tax systems for similar income taxes paid to other countries (foreign taxes).〔For the US, see . For the UK, see (Part XVII of Chapter IV Income and Corporation Tax Act of 1988 ), beginning at section 788, (hereafter UK ICTA88/Sxxx) as amended. For Canada, see Income Tax Act (section 126 ) (referring to a "deduction from the tax for the year") (hereafter, Canada ITA Section xx). For Singapore, see (Sections 50 and 50A ) of the Income Tax Act (hereafter Singapore ITA section 50 or 50A). For detailed rules on each country's system of taxation, see the article for that country.〕 This is generally referred to as a foreign tax credit. Amounts in excess of income tax are usually nonrefundable.〔, (Canada ITA section 126.1(b) ).〕 The credit is generally limited to those taxes of a nature similar to the tax against which the credit is allowed (for example, taxes on net income after allowance of deductions).〔 and , which provides all of the detail rules below except conditions imposed by levying body. Also, see Canada ITA section 126(4).〕 Rules defining taxes eligible for credit may refer to one or more of the following characteristics of such tax: *Nature of the foreign levy (compulsory, payment for services, optional, discretionary as to rate, etc.), *Whether the foreign country allows a similar credit, *Whether the two countries have a tax treaty, *Nature of the base on which the levy is imposed (gross receipts, income net of deductions, deemed profits, property, or other basis), *Form in which payments are made (withholdings, payment by check or giro, or payments in kind), *Political considerations (boycotts by taxing country, etc.), *Conditions imposed by levying body on taxpayers (information disclosure, etc.), or *Services or property provided by levying body or related persons as a result of the tax. For example, the system in the United States allows FTC, subject to limitations, for foreign compulsory levies based on net income or withheld from gross receipts.〔.〕 It also denies FTC for taxes paid to countries requiring participation in certain boycotts〔(j), 〕 or taxes paid in exchange for goods or services provided by the taxing authority for services.〔(f) and , among others.〕 The United Kingdom allows FTC, subject to limitations, for foreign taxes of a nature similar to the income or corporation tax. This is allowed under tax treaties〔(ICTA88/S788 ).〕 or as a unilateral credit.〔(ICTA88/S790 ).〕 Canada similarly allows credits but limits the portion of foreign tax subject to deduction with respect to an oil or gas business.〔(Canada ITA section 126(5) ).〕 Some countries do not tax persons whether resident of that country or not except on income considered to be from sources in that country or remitted to that country. Those countries tend to allow FTC only to residents and only with respect to taxes imposed on the income subject to tax in the home country. Singapore grants FTC only to residents and only with respect to income taxed in Singapore.〔(Singapore Income Tax Act Sections 50 and 50A ).〕 Many systems specify the time at which a foreign levy meeting the requirements for FTC becomes eligible for such credit, such as when the levy is withheld from income or otherwise paid or settled in cash or property.〔(a), .〕 Some systems allow a credit when the tax would be properly chargeable under the domestic system.〔This is implicit in the UK system.〕 Others allow FTC by reference to the time the foreign item of income is chargeable to home country income tax.〔(India Income Tax Act section 91(1) ). Note that India imposes tax based on income of the preceding year.〕 Some systems allow the credit with the tax would be recognized in financial statements. Some systems base the timing of recognition on the method of accounting of the taxpayer, possibly with an election by a cash basis taxpayer to recognize the tax at the time properly accrued.〔(a), .〕 Many income tax treaties require that the governments party to the treaty grant FTC even if the domestic law of such party do not grant such credit. Federal systems, such as those in Canada, Switzerland, and the US, may have different rules for allowing a credit for extra-jurisdictional credits at the federal and state levels. Such rules may differ among sub-federal (provincial, cantonal, state) jurisdictions. Thus, for example, Canadian and US federal governments allow credits from all foreign levels,〔Canada ITA section 126(6)(a), (a).〕 while Canadian provinces and US states tend to allow a credit for income taxes paid to other provinces and states but not for taxes paid to sovereign jurisdictions (countries).〔See, for example, New York State personal income tax form (IR-112-R ).〕 Sub-federal taxes may or may not be covered by income tax treaties.〔Taxes covered by the treaty tend to be explicitly defined in each treaty. For instance, the (US/Switzerland treaty ), Article 2, defines Swiss covered taxes as "the federal, cantonal, and municipal taxes on income" but limits US taxes to taxes under the Internal Revenue Code, which does not include state taxes.〕 抄文引用元・出典: フリー百科事典『 ウィキペディア（Wikipedia）』 ■ウィキペディアで「foreign tax credit」の詳細全文を読む スポンサード リンク
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