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税收抵免是指纳税人在居住国汇总计算缴纳其国内外收入的所得税时,准予扣除其在国外已缴纳的税款。美国从一九一八年开始,就实行了税收抵免政策,允许纳税人可以在国内缴纳的所得税中抵免在国外已纳的税款。但在实际执行中,按美国《国内收入法典》有关章节规定的计算结果分析,税收抵免政策出现了下列一些问题。为便于计算分析,现假设美国联邦所得税的税率为50％,美国安姆公司在国内外的所得收入均为美国的应税所得。第一种情况:假定安姆公司从国外一家子公司获得1000美元后的股息,已在国外按30％的税率缴税,则在国内按照扣除法或税收抵免法两种办法来分别计算,其税收负担不一样。
Tax credit refers to the taxpayers in the country of residence to calculate and pay the income tax income at home and abroad, shall be allowed to deduct their tax already paid abroad. Since 1918, the United States has implemented a tax credit policy that allows taxpayers to offset tax paid domestically from domestic income tax paid. However, in actual implementation, according to the calculation results stipulated in the relevant sections of the U.S. Internal Revenue Code, there are some problems with the tax credit policy. To facilitate the calculation and analysis, it is assumed that the tax rate of the federal income tax in the United States is 50%. The income earned by Amcor at home and abroad is the taxable income of the United States. The first case: Suppose An Amcor obtained a dividend of 1000 U.S. dollars from a foreign subsidiary and paid the tax at a rate of 30% in foreign countries, then calculated separately according to the deduction method or the tax credit method in China. Its tax burden is different.