Traders or merchants who qualify for the trader's tax status (TTS) as a sole proprietorship, S-Corp or partnership (including hedge funds), wonder if they should use the tax treatment...
Posted by John Pournaras Agency on 04/09/2019
13.3.1 [a] Taxation of Gains by Non-resident Aliens and Foreign CorporationsThe United States generally imposes a flat 30 percent tax, collected by withholding, on the gross amount...
Posted by The Accounting and Tax on 11/22/2018
7.3.1 [a] U.S. Taxation of Income of Foreign PersonsForeign persons generating income from U.S. sources are potentially subject to one, or both, of two U.S. federal taxation regimes....
Posted by The Accounting and Tax on 09/09/2017
6.3.1 Taxation of Investments in U.S Real Property by Canadian Investors6.3.1 (a) - IntroductionThere are many tax and legal considerations that must be weighed before making an investment...
Posted by The Accounting and Tax on 07/28/2016
5.3.1[a] U.S. Taxation of Foreign PersonsThe U.S. tax treatment of foreign persons and foreign-related transactions depends primarily on three criteria:1 – Whether the income earned...
Tax issues of foreign persons in the United States...
Posted by The Accounting and Tax on 02/16/2016
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...
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