Unit 8 - Chapter 8 Treatment of Foreign-Owned US Business...

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Chapter 8 Treatment of Foreign-Owned US Business Income ECI – effectively connected income Look at the activity, agent, marketing activity, inventory , approving orders If you have … Considerable Continuous Regular To trade or business. Minimus rule Real Property- does not automatically mean trade or business Rental income –make election – effectively connected income – Exception? Tax on income (GECEN HAFTAKİ KONU, seçim yapıyorsun) Section 881- 882 - Tax on income of foreign corporations connected with United States business (a) Imposition of tax (1) In general A foreign corporation engaged in trade or business within the United States during the taxable year shall be taxable as provided in section 11 , 55 , 59A , or 1201 (a) on its taxable income which is effectively connected with the conduct of a trade or business within the United States. (2) Determination of taxable income In determining taxable income for purposes of paragraph (1), gross income includes only gross
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