|German to English translations [PRO]|
Bus/Financial - Law: Taxation & Customs
|German term or phrase: schädliche Passiveinkünfte|
|"Der Tätigkeitsschwerpunkt der ausländischen Gesellschaft besteht darin, Einnahmen aus Management und Consultingtätigkeiten zu erzielen. Einnahmen aus Zinsen, ... werden nicht erzielt. Demnach ist der Missbrauchsgrund der schädlichen Passiveinkünfte nicht erfüllt"|
I don't know how to translate "schädlich" in this context.
Thanks for your help in advance.
|adverse passive income|
Royalty income can be ADVERSE for personal holding company status and PASSIVE INVESTMENT INCOME of S corporation. ...
It can also be translated as:
Income that would be subject to taxation, however, is not as narrow as would be expected from the characterization in the proposal of "investment income" but includes all "passive" income such as rent, royalties, interest, dividends, and capital gains.
The branch is not likely to be paying foreign tax on this PASSIVE INCOME, and even if the taxpayer’s foreign business operations have generated excess foreign tax credits, those credits will not be available here because of the basket limitations that apply to the use of foreign tax credits.
Foreign subsidiary. If the funded plan is sponsored by a foreign subsidiary of the U.S. multinational, the potential consequences are more complicated, but no less DETRIMENTAL.
Selected response from:
Local time: 01:57
|Thank you to all of you for your help!|
I used "adverse passive income" so the grade should really go to the third answerer as well. Unfortunately, I have to pick one.
4 KudoZ points were awarded for this answer
loss-making passive income
'passive' in this context probably means interest-free
| Mats Wiman|
Local time: 01:57
Native speaker of: Swedish
PRO pts in category: 4
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