Abstract

http://ssrn.com/abstract=2097104
 


 



Foreign Tax Credit versus Foreign Earned Income Exclusion Under the New Law


James G. S. Yang


Montclair State University - Accounting, Law & Taxation

June 30, 2012


Abstract:     
This paper deals with the recent new law concerning foreign earned income exclusion and foreign housing cost allowance exclusion. It points out that the former is $95,100 in 2012, while the latter has a certain limit depending on the location in the world. Nevertheless, both exclusions do not give rise to the reduction of marginal tax rate. Instead, a taxpayer’s tax bracket is determined as if no exclusions were taken. This new tax rule has far-reaching consequences on a U.S. expatriate’s foreign tax credit and tax liability. This paper demonstrates many examples. It also investigates the problem of foreign qualified dividend in determining foreign tax credit. This paper further develops many tax planning strategies for foreign tax credit. The decision depends on whether a foreign country has high or low income and tax rate.

Number of Pages in PDF File: 15

Keywords: Foreign tax credit, foreign earned income exclusion, foreign housing cost allowance, foreign-source income, worldwide income, qualified dividend, rate differential portion, active income, passive income

working papers series





Download This Paper

Date posted: July 1, 2012 ; Last revised: October 31, 2012

Suggested Citation

Yang, James G. S., Foreign Tax Credit versus Foreign Earned Income Exclusion Under the New Law (June 30, 2012). Available at SSRN: http://ssrn.com/abstract=2097104 or http://dx.doi.org/10.2139/ssrn.2097104

Contact Information

James G. S. Yang (Contact Author)
Montclair State University - Accounting, Law & Taxation ( email )
Upper Montclair, NJ 07043
United States
973-655-7129 (Phone)
973-655-7968 (Fax)
Feedback to SSRN


Paper statistics
Abstract Views: 2,690
Downloads: 803
Download Rank: 16,336

© 2014 Social Science Electronic Publishing, Inc. All Rights Reserved.  FAQ   Terms of Use   Privacy Policy   Copyright   Contact Us
This page was processed by apollo8 in 0.250 seconds