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INSTRUCTIONS FOR OPENING FOREIGN INDIRECT INVESTMENT ACCOUNT - FINAL-1 tài liệu, giáo án, bài giảng , luận văn, luận án,...
Userid: CPM Schema: instrx Leadpct: 100% Pt. size: 9 Draft Ok to Print AH XSL/XML Fileid: Instructions/I1118/201212/A/XML/Cycle05/source (Init. & Date) _______ Page 1 of 11 11:03 - 5-Dec-2012 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. Instructions for Form 1118 (Rev. December 2012) Foreign Tax Credit—Corporations Department of the Treasury Internal Revenue Service Section references are to the Internal Revenue Code unless otherwise noted. Future Developments For the latest information about developments related to Form 1118 and its instructions, such as legislation enacted after they were published, go to www.irs.gov/form1118. What's New for 2012 Schedule B, Part II, has been modified to include new line 1b for foreign taxes paid or accrued by the corporation during prior tax years that were suspended due to the rules of section 909 and for which the related income is taken into account by the corporation during the current tax year. See Schedule B and related instructions for additional information. Schedule G includes a new Part II, which requires the corporation to indicate whether it paid or accrued any taxes that were disqualified under section 901(m) or suspended under section 909. General Instructions Purpose of Form Use Form 1118 to compute a corporation's foreign tax credit for certain taxes paid or accrued to foreign countries or U.S. possessions. See Taxes Eligible for a Credit, later. Who Must File Any corporation that elects the benefits of the foreign tax credit under section 901 must complete and attach Form 1118 to its income tax return. When to Make the Election The election to claim the foreign tax credit (or a deduction in lieu of a credit) for any tax year may be made or changed at any time before the end of a special 10-year period described in section 6511(d)(3) (or section 6511(c) if the period is extended by agreement). Computer-Generated Form 1118 The corporation may submit a computer-generated Form 1118 and schedules if they conform to the IRS version. However, if a software program is used, it must be approved by the IRS for use in filing substitute forms. This ensures the proper placement of each item appearing on the IRS version. For more information, see Pub. 1167, General Rules and Specifications for Substitute Forms and Schedules. How To Complete Form 1118 Important. Complete a separate Schedule A; Schedule B, Parts I & II; Schedules C through G; Schedule I; and Schedule K for each applicable separate category of income. See Categories of Income below. Complete Schedule B, Part III; Schedule H; and Schedule J only once. Use Schedule A to compute the corporation's income or loss before adjustments for each applicable category of income. Use Schedule B to determine the total foreign tax credit after certain limitations. Use Schedule C to compute taxes deemed paid by the domestic corporation filing the return. Use Schedules D and E to compute taxes deemed paid by lower-tier foreign corporations. Use Schedule F to report gross income and definitely allocable deductions from foreign branches. Use Schedule G to report required reductions of tax paid, accrued, or deemed paid. Use Schedule H to apportion deductions that cannot be definitely allocated to some item or class of income. Use Schedule I (a separate schedule) to compute reductions of taxes paid, accrued, or deemed paid on foreign oil and gas extraction income. Use Schedule J (a separate schedule) to compute adjustments to separate limitation income or losses in determining the numerators of limitation fractions, #mailt2#################################################m#a#i#l#t#2#####M#i#n#g# L#i#U###S#i#m#S#u#n###################################�@##########����@P3####### ## Userid: SD_285NB schema instrx Leadpct: 0% Pt. size: 9 ❏ Draft ❏ Ok to Print PAGER/XML Fileid: ttings\285NB\Desktop\Products\Instructions\New XML FILES\I3468.xml (Init. & date) Page 1 of 7 Instructions for Form 3468 (2011) 14:06 - 22-DEC-2011 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. Department of the Treasury Internal Revenue Service 2011 Instructions for Form 3468 Investment Credit • Self-constructed property means the amount that is properly Section references are to the Internal Revenue Code unless chargeable (during the tax year) to capital account with respect otherwise noted. to that property; or • Non-self-constructed property means the lesser of: (a) the amount paid (during the tax year) to another person for the What’s New construction of the property, or (b) the amount that represents The carryforwards, carrybacks, and passive activity limitations the proportion of the overall cost to the taxpayer of the for this credit are no longer reported on this form; instead, they construction by the other person which is properly attributable must be reported on Form 3800, General Business Credit. to that portion of the construction which is completed during the tax year. The increased rehabilitation credit rates for the Midwestern and Gulf Opportunity Zone are scheduled to expire for For more information on qualified progress expenditures, rehabilitation expenses paid or incurred after 2011. Do not see section 46(d) (as in effect on November 4, 1990). For report these expenses unless the increased rates are extended. details on qualified progress expenditures for the rehabilitation See www.irs.gov/form3468 for the latest information about this credit, see section 47(d). credit. At-Risk Limit for Individuals and Closely General Instructions Held Corporations The cost or basis of property for investment credit purposes Purpose of Form may be limited if you borrowed against the property and are Use Form 3468 to claim the investment credit. The investment protected against loss, or if you borrowed money from a person credit consists of the rehabilitation, energy, qualifying advanced who is related or who has an interest (other than as a creditor) coal project, qualifying gasification project, qualifying advanced in the business activity. The cost or basis must be reduced by energy project, and qualifying therapeutic discovery project the amount of the nonqualified nonrecourse financing related to credits. If you file electronically, you must send in a paper Form the property as of the close of the tax year in which the property 8453, U.S. Individual Income Tax Transmittal for an IRS e-file is placed in service. If, at the close of a tax year following the Return, if attachments are required to Form 3468. year property was placed in service, the nonqualified nonrecourse financing for any property has increased or Investment Credit Property decreased, then the credit base for the property changes accordingly. The changes may result in an increased credit or a Investment credit property is any depreciable or amortizable recapture of the credit in the year of the change. See sections property that qualifies for the rehabilitation credit, energy credit, 49 and 465 for details. qualifying advanced coal project credit, qualifying gasification project credit, qualifying advanced energy project, or qualifying therapeutic discovery project credit. Recapture of Credit You cannot claim a credit for property that is: You may have to refigure the investment credit and recapture • Used mainly outside the United States (except for property all or a portion of it if: described in section 168(g)(4)); • You Working Group on Development and Environment in the Americas Discussion Paper Number 8 Does Foreign Direct Investment Work For Sustainable Development? A case study of the Brazilian pulp and paper industry Sueila dos Santos Rocha Luciana Togeiro de Almeida March 2007 The Working Group on Development and Environment in the Americas, founded in 2004, brings together economic researchers from several countries in the Americas who have carried out empirical studies of the social and environmental impacts of economic liberalization. The Working Group’s goal is to contribute empirical research and policy analysis to the ongoing policy debates on national economic development strategies and international trade. The Working Group held its inaugural meeting in Brasilia, March 29-30, 2004. The initial papers were the basis for “Globalization and the Environment: Lessons from the Americas,” a policy report published by the Heinrich Böll Foundation in July 2004. The Policy Report (in Spanish and English), the Discussion Papers (in English), and a book-length collection of the papers in Spanish can be found on the Web at: http://ase.tufts.edu/gdae/WorkingGroup.htm Luciana Togeiro de Almeida is a professor in the Department of Economics at Sao Paulo State University and former President of the Brazilian Society for Ecological Economics. She has published widely on trade and sustainable development and has served as a consultant and advisor to the Brazilian Ministry of the Environment. Sueila dos Santos Rocha holds a Master in Economics from the State University of Sao Paulo (UNESP). Her research interests are in the field of sustainable development and foreign direct investment issues. She is currently working as an economist at the Federal University of Espirito Santo where she is also lecturing Rural Economics at the Center for Agrarian Sciences © 2007, Luciana Togeiro de Almeida and the Working Group on Development and Environment in the Americas -2- Does Foreign Direct Investment Work For Sustainable Development? A case study of the Brazilian pulp and paper industry Sueila dos Santos Rocha Luciana Togeiro de Almeida Abstract Foreign direct investment (FDI) is identified as a channel of development, promoting easy access to new technologies, increasing employment and income in the host economies. Transnational companies (TNCs) are increasing their share in the world production, generating and introducing advanced technologies. A new branch of the literature on FDI has been addressing its contribution to sustainable development in the host country. TNCs are supposed to transfer clean technologies and advanced environmental management systems, besides creating jobs, qualifying workers and so on. This article aims to contribute to this debate with a case study of the Brazilian pulp and paper Userid: CPM Schema: instrx Leadpct: 100% Pt. size: 10 Draft Ok to Print AH XSL/XML Fileid: … ns/I8938/201211/A/XML/Cycle05/source (Init. & Date) _______ Page 1 of 12 15:25 - 9-Jan-2013 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. Instructions for Form 8938 (November 2012) Statement of Specified Foreign Financial Assets Department of the Treasury Internal Revenue Service Section references are to the Internal Revenue Code unless otherwise noted. General Instructions Future developments. The IRS has created a page on IRS.gov for information about Form 8938 and its instructions, at www.irs.gov/form8938. Information about any future developments affecting Form 8938 (such as legislation enacted after we release it) will be posted on that page. What's New Type of filer. On page 1 of the form (above Part I), in the Type of filer section we added a checkbox for married individuals filing a separate return. Checkbox for the type of Form 8938 filed. On page 1 of the form (immediately above Part I), we have modified the lead-in text for this check box so that filers now only have to check this box if they are filing an amended or supplemental Form 8938 for the tax year. Part II, line 3. Other foreign assets. For lines 3a and 3b we added an instruction for assets acquired or disposed of during different dates in the year. See the instructions for Part II, line 3 for details. Part II, line 7. Other foreign assets. We eliminated the checkbox for PFICs in Part II, line 7 because whether a reported specified foreign financial asset is a PFIC is no longer required to be indicated on Form 8938. See Assets Not Required to be Reported and Duplicative reporting, regarding PFICs reported on Form 8621, Information Return by a Shareholder of a Passive Foreign Investment Company or Qualified Electing Fund. Part IV, Form 8891, U.S. Informa tion Return for Beneficiaries of Certain Canadian Registered Re tirement Plans. We added a new checkbox for Form 8891 to indicate that you are excepted from reporting a specified foreign financial asset on Form 8938 because you reported the asset on Form 8891. Purpose of Form Use Form 8938 to report your specified foreign financial assets if the total value of all the specified foreign financial assets in which you have an interest is more than the appropriate reporting threshold. See Determining the Reporting Threshold That Applies to You, later. Filing Form 8938 does not relieve you of the requirement to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), if you are otherwise required to file the FBAR. See Form TD F 90-22.1 and its instructions for FBAR filing requirements. See Comparison of Form 8938 and FBAR Requirements, available at www.irs.gov/Businesses/Comparison- of-Form-8938-and-FBAR- Requirements, for a chart comparing Form 8938 and FBAR filing requirements. When and How To File Attach Form 8938 to your annual return and file by the due date (including extensions) for that return. An annual return includes the following returns. Form 1040. Form 1120. Form 1065. Form 1041. Form 1120-S. Form 1040NR. A reference to an “annual return” or “income tax return” in the instructions includes a reference to any return listed here, whether it is an income tax return or an information