Camp proposal - 95% Deduction for certain CFC dividends Transition rule deemed inclusion of accumulated foreign earnings
{"Image DocumentName": "Camp proposal - 95% Deduction for certain CFC dividends Transition rule deemed inclusion of accumulated foreign earnings", "Image ImageDescription": "In the last taxable year ending before January 1, 2013, the subpart F income of a specified 10-percent owned foreign corporation would be increased by the corporation\u2019s accumulated deferred foreign income determined as of the close of such taxable year. The inclusion of this subpart F income would be subject to an 85% deduction, for an effective tax rate of 5.25% No credit or deduction allowed for foreign taxes paid (or deemed paid) with respect to deductible portion. Taxpayer could elect to pay tax liability in up to eight installments (including interest); certain events can accelerate payment of tax. The accumulated foreign income so included would be subject to the 95% DRD when distributed, which at a 25% tax rate would represent an additional tax of 1.25%", "Image XResolution": "37", "Image YResolution": "37", "Image ResolutionUnit": "Pixels/Centimeter", "Image Software": "SlidePlayer", "Image YCbCrPositioning": "Centered"}