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Unformatted text preview: foreign office of a U.S. bank or other financial institution or (b) portfolio interest earned on registered or unregistered obligations issued by U.S. taxpayers? They consider the following factors in determining whether the interest is business income subject to U.S. taxation: (1) was the interest generated by an asset held or used in the conduct of a U.S. trade or business (i.e., asset-use test) or (2) are the taxpayer's activities a material factor in the realization of the interest income (i.e., business activities test)?...
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- Spring '11