Technical Committee on Business Taxation
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1996-01

Comparison and Assessment of the Tax Treatment of Foreign-Source Income in Canada, Australia, France, Germany and the United States

Brian J. Arnold, Jinyan Li and Daniel Sandler

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Abstract

This report deals with selected aspects of the tax treatment of foreign-source income in Canada, Australia, France, Germany and the United States. It does not attempt to be comprehensive. It emphasizes the structural features of each country's tax system with respect to the taxation of foreign-source income derived by resident corporations. In particular, the report focusses on the taxation of dividends from foreign corporations, controlled foreign corporation (CFC) rules, foreign investment fund rules, and source of income and expense rules. The description of each country's tax law follows a standard format to facilitate comparisons.

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