[section] 901(b)(1) of the Internal Revenue Code and noted that "income, war profits, and
excess profits taxes ...
Nonetheless, McLure and Zodrow demonstrate that from an economic standpoint, both of these taxes are equivalent to an
excess profits tax. A substance-over-form approach could result in these taxes' being deemed creditable.
The corporate tax reform movement stalled in part because the focus turned to repealing the
excess profits tax. The
excess profits tax had long been opposed by business, but this opposition only grew stronger with the end of the war.
Both cases raise questions about what constitutes an
excess profits tax, when foreign taxes are creditable, and even how Treasury regulations should be interpreted.
Initial plans levy on financial transactions but it is not believed that the IMF is giving serious consideration to that and is now said to be looking at two central tax recommendations - the
excess profits tax and a balance sheet tax that has been proposed by Barack Obama's administration and already implemented in Sweden.
[5] An additional "declared value"
excess profits tax, based on profits in excess of a percentage of the value of corporate stock, was in effect from 1933 through 1945.
[7] From June 1940 to the end of 1945, a tax on profits in excess of average prewar earnings was also imposed, it was taken into account, as either a deduction or a credit, for the income tax and the other
excess profits tax.
excess profits taxes was capped at a given percentage of income
This is possible because IRC section 56(b)(1)(A) requires the taxpayer, in computing the AMT taxable income, to add back to taxable income any tax described in IRC section 164(a)(3) (state and local, and foreign, income, war profits, and
excess profits taxes) and IRC section 164(b)(5)(A)(i), which includes, by inference, state and local general sales taxes in IRC section 164(a)(3), causing the deduction for state and local general sales taxes to also be added back in computing AMT.
22 Federal income and
excess profits taxes, IRS 358.4
Finally, the instructions require the translation of the provision for income, war profits, and
excess profits taxes (line 20 of Schedule C) at the average exchange rate for the year.