TAX 9869 Lecture Notes - Lecture 47: Foreign Corporation, Capital Gain, Fungibility

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17 Jul 2020
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Unit 9: treatment of foreign-owned united states business income: overview. U. s. source investment income that is not effectively connected to a united states trade business/ may be subject to a flat 30% withholding tax. U. s trade/business income that is effectively connected with the conduct of such trade/business is potentially taxed at regular rates. 9. 01 engaged in a trade/business in the u. s. A u. s. trade/business is generally characterized by progression, continuity, or sustained activity that occurs during some substantial portion of the taxable year: rev. 9. 02 attribution though agents: to be considered a dependent agent it is sufficient that the u. s. based person or entity either acts exclusively or near exclusively for such foreign person. 9. 03 performance of services as a trade or business. Ruling 55-17, the service found that license treatment should prevail if the personal services are only nominally valuable apart from the license itself: ex.

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