The U.S. taxes businesses generally at rates from 15% to 35%. However, the graduated rates for individuals are different from those for corporations. United States Code Title 26 sections 1 and 11, hereafter 26 USC 1 and 11
U.S. rules limit the credit by categories based on the nature of the income. 26 USC 904. For 20 years prior to changes first effective in 2007, there were at least nine such categories. These included, e.g., financial services income, high-taxed income, other passive income, and other (operating or general) income. UK rules provide for separate limitations based on the schedule of income on which UK tax is computed. Thus, credits were separately limited for salaries versus dividends and interest.
E.g., under U.S. rules, the credit is limited to U.S. tax on foreign source taxable income for a particular category. The rules for determining source for taxation of foreign persons (sections 861-865) apply in computing such credit, and detailed rules are provided in regulations (above) for allocating and apportioning expenses to such income.
Anti-deferral and other shifting measures have also been combatted by granting broad powers to revenue authorities under "general anti-avoidance" provisions. See a discussion of Canadian GAAR a CTF articleArchived 2010-02-15 at the Wayback Machine.
Income Tax ActArchived 2013-09-27 at the Wayback Machine, Ministry of Finance, Revenue and Tax Administration of the Turkish Republic of Northern Cyprus, 2010. (in Turkish)
E.g., Egypt limitsArchived 2009-10-07 at the Wayback Machine the credit to the Egyptian income tax "that may have been payable with respect to profits from works performed abroad," but without a thorough definition of terms. Article (54).
Christians, Allison (April 2005). "Tax Treaties for Investment and Aid to Sub-Saharan Africa: A Case Study". Northwestern Public Law Research Paper No. 05-10; Northwestern Law & Econ Research Paper No. 05-15. SSRN705541.
Income Tax ActArchived 2013-09-27 at the Wayback Machine, Ministry of Finance, Revenue and Tax Administration of the Turkish Republic of Northern Cyprus, 2010. (in Turkish)
E.g., Egypt limitsArchived 2009-10-07 at the Wayback Machine the credit to the Egyptian income tax "that may have been payable with respect to profits from works performed abroad," but without a thorough definition of terms. Article (54).
Anti-deferral and other shifting measures have also been combatted by granting broad powers to revenue authorities under "general anti-avoidance" provisions. See a discussion of Canadian GAAR a CTF articleArchived 2010-02-15 at the Wayback Machine.
