What are the major U.S. tax issues that apply to an inbound transaction? The major U.S. tax
Question:
What are the major U.S. tax issues that apply to an inbound transaction?
The major U.S. tax issues that apply to an inbound transaction involve
1 ) whether the non - U.S. person has nexus in the United States ( is subject to U.S. taxation ),
2 ) whether the income earned by the non-U.S. person is from U.S. sources,
3 ) the type of U.S. source income earned ( income effectively connected with a U.S. trade or business ( ECI ) or income that is fixed, determinable , annual, or periodic ( FDAP ), and
4 ) whether a treaty applies to change the U.S. taxation of the transaction that otherwise would apply.
please provide detail of each one.
Taxation Of Individuals And Business Entities 2015
ISBN: 9780077862367
6th Edition
Authors: Brian Spilker, Benjamin Ayers, John Robinson, Edmund Outslay, Ronald Worsham, John Barrick, Connie Weaver