Code Section 7701 (b)(2)(A)(iii) U.S residency start date depends on two things: ü Residency is established under the green card test. ü Residency is established...
On Tuesday January 13, the IRS Commissioner sent an email to his employees discussing the IRS budget for 2015. It stated in the email that, the IRS will "have no choice but to do less...
Resident aliens in the United States are taxed on their world wide income. Nonresident aliens are taxed on their U.S source income. Code Section 7701(b)(1)(A) An alien will be considered...
Posted by The Accounting and Tax on 01/05/2015
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...
If a taxpayer has personal relations with one country (Home) and derives income from another country (Host) it can cause a double taxation issue. The host country will most likely...
Multinational Companies do lot of intercompany transactions. U.S manufacturers market their products in foreign countries through their subsidiaries. Domestic parent companies sometimes...
Ref Code Section 871 (b) and 882: According to these code sections if a foreign person is engaged in a U.S trade or business, he is subject to U.S taxes for any income that is connected...
Posted by The Accounting and Tax on 12/10/2014
Foreign Corporations and non-resident aliens who have a U.S source income are subject to U.S Taxation. According to codes section 871 (b) and 882, all Foreign Persons are taxed at...
If a domestic corporation has a foreign subsidiary, this subsidiary will usually maintain its books and records in the currency of the country where it exists. If this subsidiary repatriates...