It would seem, therefore, that domestic corporations
can donate to a political party, or candidate, for the purpose of a partisan political activity.
Further, the domestic corporation
must have "foreign-derived
"The Act changes the taxation of domestic corporations
from a worldwide tax system to a hybrid territorial tax system by establishing a limited participation exemption system.
As a complement to the new GILTI regime, the new legislation introduced a somewhat similar reduced-tax regime for foreign "intangible income" earned directly by domestic corporations
that parallels the reduced rate of tax that applies to such income earned by foreign subsidiaries.
Regulated investment companies--A regulated investment company (RIC) is a domestic corporation
registered as a management company or unit investment trust under the Investment Company Act of 1940 (ICA), or elected to be treated as a business development company under the ICA, or (with exceptions) a common trust fund or similar fund.
If, in contrast with a domestic corporation
, a direct foreign corporate owner had instead been involved, the result may have differed in a real and substantial sense.
Section 1(h) (11), provides that net capital gain for purposes of Section 1(h) means net capital gain (determined without regard to section 1 (h)(11)) increased by "qualified dividend income." Qualified dividend income means dividends received during the taxable year from domestic corporations
and qualified foreign corporations.
The IRS has taken the position, however, that the doctrine of equitable recoupment applies only when the two taxes are paid by the same taxpayer; because the domestic corporation
in question had paid the income taxes under the assessment and the admitted carrier had paid the excise tax (notwithstanding that the excise tax related to premium paid by the domestic corporation
), the theory of equitable recoupment would therefore not apply.
The effect of this rule is that domestic corporations
owning at least 80% of the vote and value of the stock of another corporation that itself operates a trade or business are entitled to an ordinary loss if the affiliated company's stock becomes worthless.
(5) The transaction involved the acquisition of a domestic corporation
"More often than not a domestic corporation
holds the real estate and the domestic shares are owned by the offshore corporation," he explained.
It said 99 percent of FTC is owned by another domestic corporation
and has no individual stockholders to receive dividends.