Every country has a different policy wrt taxation of foreign source
income. For example, the US taxes FSI at the rate of the difference
between the tax paid where the income was generated and the tax rate
in the US when the income is repatriated. The Netherlands, on the
other hand, does not tax previously taxed income upon repatriation. My
question is: what are the foreign source income policies, briefly
stated, for the largest 200 economies in the world
(http://www.photius.com/rankings/gdp_2003_0.html).

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Clarification of Question by mjpolanco-ga on 12 Apr 2005 15:12 PDT

Please counteroffer if you believe you can get foreign source income
information for 50+ countries. This is acceptable.

Dear Mjpolanco, 

I can only speak for myself, but I wonder if such information - unless
could be found somehwere in a ready-made research - would be
beneficial for any Researcher to do for $75. Researchers receive 3/4th
of the listed price. Even if each of the 200 countries takes only a
couple of minutes to research (and it will probably take more than
that), the Researcher would get $8 an hour.

Dear politicalguru,

I agree that doing the research by hand is unlikely to make sense at
the given price. Yet it appears to me that a researcher with
background knowledge in the field may know where to locate the
"ready-made research" that would make this a profitable endeavor.

Marcos

Hi,
In the first place, 200 countries probably exceeds the number of
countries that have a policy on taxation of foreign sourced income,
and 200 is pretty close to all the countries on earth (your link with
231).
Keep it realistic.  It is nice that you want to let a researcher earn
3/4 of $ 75 to give you an answer, but as Politicalguru has pointed
out,  they know what their time is worth and how much effort may be
involved.
As your example points out, the question is interesting  - the
differences in the taxation policies.  Realistically, however, this
can only be interesting for someone considering investing in one of
several countries.  Yes, as an academic exercise, it may be
interesting to have the information for a greater number of countries,
which reminds me that some international accounting firms have
booklets with a survey of taxation in different countries.

What do you want to do with the info, if you could have it?
Regards,

Dear myoarin-ga,

Regarding the number of countries involved, the question of foreign
source income is interesting to the extent that you are taking the
profits in one country and pumping it into another. For example, $100
for income in the US sent to the EU probably turns into $67, given 33%
taxation. But generating the same income in Singapore potentially
delivers $100 to the EU, because Singapore is a tax haven for certain
industries. That is why the number of countries is so high. A company
considering investing in Puerto Rico (where I live) may have other
operations in Canada, India and Ghana. They want to know what whether
they can pump PR profits easily into these countries.

Regarding the realism of paying $75 for the information, as you point
out, "some international accounting firms have booklets with a survey
of taxation in different countries"...is it worth the time of the
researchers to locate this guide? Perhaps then counteroffer to me, "I
cannot get you 200 but I do have 76." Well, that is an interesting
counteroffer to me.

Regarding the use of the information, I help companies build their
businesses in Puerto Rico and sometimes they request this information.
Whereas I do not pretend to provide tax advice, it would be nice to
give them a general idea.

Thanks.

And thank you for your explanation.  Makes sense.  

Another side of the matter is intra-group pricing, something that
maybe be behind the ongoing lack of profits in GM's Opel AG subsidiary
in Germany, where I live, which has relatively high corporate income
taxes.  There is a suspicion that the pricing of intra-group
transactions may be the reason for this, even perhaps to the extent of
letting Opel appear to have  - or really have - such difficulties that
it justifies laying of staff or bargaining for lower wages, with the
real threat of transfering more production to countries with much
lower costs.

I hope a researcher will be able to help you.