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CFA Level 3
Topic: Private Wealth Management
Reading: Taxes and Private Wealth Management in a Global Context
Residence-source conflicts are the most common source of double taxation. Foreign tax credit provisions or double taxation treaties help to mitigate/eliminate double taxation. The foreign tax credit provisions we will discuss are:
1) Credit Method
Taxpayer pays source jurisdiction in full.-
Residence jurisdiction reduces tax rate by the amount paid to the source jurisdiction (limited to a minimum of zero).
2) Exemption Method
Taxpayer pays source jurisdiction in full.
Residence jurisdiction exempts taxpayer on foreign-sourced income.
3) Deduction Method
Taxpayer pays source jurisdiction in full.
Taxpayer pays residence jurisdiction, at a discounted rate.
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