Page 152 - International Taxation IRS Training Guides
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Overview of Pre-TCJA US Tax System
rate
35% statutory
(reduced by FTCs)
on USP
35% on subpart F USP
income
income (reduced by
FTCs)
Deferral of active
income until 35% on branch income
repatriation (reduced by FTCs)
CFC FBR
7
