TAX 9869 Lecture Notes - Lecture 35: Payment, Foreign Corporation

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17 Jul 2020
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Non-u. s. persons, either, indiv/corp doing biz in us. Review: residency- nonresident alien can become resident of us for tax purposes if, meets green card test or, spt. When you have non-us person who has activity in us, us could have right to tax income. Sourcing important for two reasons: nonus person subject to us tax on income, sourcing- only take ftc against us taxes paid on foreign sourced income. Topics/tests are the same between individuals and corps. The us only taxes non us person only on us sourced income/ if the income is foreign sourced then the us has no right to tax that income. Let"s compare dividend paid from us corp to a nonus individual//div paid from non us corp to a non us individual. Example: abygail owns 100% of a us corp. she is a rez and citizen of hk. Gr: dividends sourced based on residence of payor.

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