Chapter 10 Cases - International Taxation Foreign Persons...

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International Taxation Foreign Persons Doing Business in the United States Cases Read Chapter 12. Case 1 Tamco Company, a Venezuelan corporation, engages in business in a number of unrelated activities. For the last few years, it has sold wool sweaters throughout the world, including, on infrequent occasions, the United States. Although title to the sweaters passes upon acceptance by the buyer in the United States with the result that the income is from U.S. sources, Tamco has been properly classified as not engaged in a U.S. trade or business because its contacts with the United States are not sufficiently broad to cause Tamco to be doing business in the United States. Therefore, since Tamco is not engaged in business in the United States and since its income from U.S. sources is not FDAP income, none of Tamco's income has been subject to federal income tax. In the current year, Tamco opened an office in the United States for the purpose of assembling and selling certain TV components that Tamco manufactures in Venezuela. Tamco
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Chapter 10 Cases - International Taxation Foreign Persons...

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