Читать книгу International Taxation - Adnan Islam - Страница 81

 Determine why sourcing rules are important before and after the Tax Cuts and Jobs Act (TCJA).

 Identify the steps to analyze the source of income.

 Identify how various types of income are sourced.

 Recognize how the effectively connected income (ECI) rules interact with sourcing rules with respect to dividends paid by foreign corporations.

 Recognize how the sourcing rules for use of tangible and intangible property interact with the sale of personal property sourcing rules.

 Identify the modified rule of Section 863(b), that now provides that gross income from the sale or exchange of property produced by the taxpayer will be sourced at the place of manufacture.