Resource Rent Taxation as a Basis for Petroleum Tax Policy By Foreign Governments and its Relationship to US Foreign Tax Credit Policy and Tax Law

摘要

This article explains the concepts of economic and resource rent in the area of natural resources as a basis for fiscal and tax policies by governments, and the relationship to US foreign tax credit policy and tax law. The article examines how the concepts of economic and resource rent are applied to tax the development of petroleum resources under several petroleum fiscal regimes. The changing parameters of a US creditable tax are discussed. The effect of selected income tax treaties on the creditability of foreign petroleum taxes is examined.