Chapters 9 - • Interest from foreign central banks on...

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MULTI-JURISDICTIONAL  TAXATION Foreign Persons Investing in  the United States
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General Concepts U.S. Trade or Business Profits – Regular Rates Withholding not required unless for certain types of personal services income U.S. Source Investment Income – 30% “FDAPI” Dividends, Interest, Rents, & Royalties Withholding Required of Payor Failure to withhold results in payor liability N/A for capital gains
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Exemptions From Taxation Portfolio Interest N/A for 10% shareholders, foreign Interest from bank accounts or insurance companies Dividends if more than 80% of income for the past 3 years is from foreign sources
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Unformatted text preview: • Interest from foreign central banks on banker’s acceptances. • Treaty Reductions Special Rules • Election to Treat Real Property Income as Effectively Connected – Section 871(d) allows deductions against income (I.e., interest and depreciation) • Real Property Interests – Gains from the disposition of real property interests are treated as “effectively connected” income • Exception to the exemption of capital gains from taxation. • 10% withholding required Next Week • Read Chapter 10 • Pay particular attention to the restrictions placed on branches and subsidiaries of foreign corporations....
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This note was uploaded on 09/16/2011 for the course TAX 6527 taught by Professor Andrewjudd during the Spring '11 term at University of Central Florida.

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Chapters 9 - • Interest from foreign central banks on...

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