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Foreign Activities of U.S Persons

Foreign Activities of U.S Persons

Code Section 7701 (a)(30) U.S citizens are U.S Persons and Citizens of foreign countries are U.S Persons who meet either of the following two tests: Green Card test Substantial...

Posted by The Accounting and Tax on 12/28/2014

Portfolio interest tax treaties withholding tax interest income U.S source investment Foreign earned income exclusion Foreign persons domestic corporation domestic partnership deferral from U.S taxation Subsidiaries Foreign tax rate law
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U.S Citizens in Canada – Avoiding Double Taxation

U.S Citizens in Canada – Avoiding Double Taxation

  The United States taxes its citizens on their world income even if they are not present in the United states. Canada taxes its residents on their would income. U.S Citizens...

Posted by The Accounting and Tax on 12/24/2014

Foreign Tax Credit resident alien limitation of foreign tax credit dividends rent royalties controlled foreign corporation blend high tax rate tax credit U.S Citizens in Canada Canada – USA tax treaty Avoiding Double Taxation
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Basic Principles of deciding a tax jurisdiction for international transactions

Basic Principles of deciding a tax jurisdiction for international transactions

For international transactions Governments have to decide which person and what income needs to be taxed. The basis for this can be personal relationship and economic relationship. Personal...

Posted by The Accounting and Tax on 10/28/2014

tax jurisdiction international transactions tax tax treaties tax credit exclusion If a taxpayer is resident of one country and derives income from another country it can lead to a problem of double taxation. Host country can assert taxes based on
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