Flashcards in Taxes: Taxation & Foreign Income Deck (4)
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1
Taxes:
Taxation & Foreign Income
General
General
- Treaties trump tax law
- Foreign taxpayers taxed only on US sourced income
- US Taxpayers taxed on all income
- if foreign corp receives more than 25% US Sourced income for previous 3 years, it is US sourced
2
Taxes:
Taxation & Foreign Income
Outbound Transactions
Outbound Transactions
- transfer of assets may trigger income
- if used in trade/business outside US gain is deferred unless inventory, installment obligations, or foreign currency
3
Taxes:
Taxation & Foreign Income
Controlled Foreign Corporation
Controlled Foreign Corporation
- more than 50% voting power or value of stock is owned by US citizens
Constructive Dividends:
- income not connected economically to the country where incorporated
- income from insuring risk of loss from outside the country in which organized
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