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...
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...
Basking Ridge, NJ - As 2014 comes to a close, it’s time to start thinking about how to make 2015 a success for you and your loved ones. Though there’s little consensus...
Posted by WFP Tax Partners, LLC on 12/24/2014
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...
Deemed Paid Foreign Tax Credit U.S.A If a domestic Corporation receives dividends from foreign Corporation it usually cannot claim a deduction for dividends received. These dividends...