This article describes in general terms the Japanese domestic tax treatment of the foreign income of Japanese corporations. This topic has become of increasing importance to American attorneys, businessmen and legal scholars as international trade and investment between Japan and the United States have grown. The author discusses the source rules, taxation of undistributed profits of designated tax haven subsidiaries, the foreign tax credit and domestic provisions affecting foreign income. The article concludes with an evaluation of the neutrality of the Japanese taxation of the foreign income of Japanese corporations.
Rosser H. Brockman,
Japanese Taxation of the Foreign Income of Japanese Corporations,
2 Hastings Int'l & Comp.L. Rev. 73
Available at: https://repository.uchastings.edu/hastings_international_comparative_law_review/vol2/iss1/4