1. Foreign Currency is a “part of the puzzle” when speaking about Foreign Source and Foreign Persons, which is part of the Scope of Inquiry. When a U.S. business or trade is not effectively connected, it is not represented with taxable U.S. income or U.S. dollars. It is then taxable through measures of foreign currency. Thus the taxable income does not belong to the U.S., but to the foreign country. Do you think this can be confusing to organizations?
2. A net operating loss can be beneficial for a company under certain circumstances. A company may be able to offset previous profits or future profits. There are limitations on how far back a loss can be utilized. Likewise, there is a limit to how long the benefit can be held for future use. These benefits are referred to as a “loss carryforward” or a “loss carryback”. A loss carryback can go back two years to offset a previous taxable income, and potentially receive a refund. A loss carryforward can be used up to 20 years to offset any future taxable. Do these exist in other countries?