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Last year, the tax break, known as the exception for active financing income, cost the government $3.8 billion in taxes.
We will introduce new rules that effectively apply an ultra-competitive 5.75% rate on overseas financing income.
Some argue that the surplus taxes are being used to help finance income tax cuts, which Mr. Bush wants made permanent.
One provision extends an existing exception from Subpart F for active financing income for two years.
The company said the decline stemmed from lower financing income and earnings from insurance underwriting, which offset lower overall borrowing costs.
Over-collateralisation, usually by using finance income to pay off principal on some securities before principal on the corresponding share of collateral is collected.
Financing income (e.g., interest, dividends) is generally treated as arising where the user of the financing resides.
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Net income reflects the presence of other income, lower research & development expenses, increased finance income and the presence of share of profits less losses of joint controlled entity.
Owner trusts allow credit risk to be mitigated by over-collateralization by using excess reserves and excess finance income to prepay securities before principal, which leaves more collateral for the other classes.
"Morgan's corporate finance income will take a pounding this year, but they will more than pick it up in other areas," said John Tyce, an analyst for brokerage firm Alexanders Laing & Cruickshank.