Читать книгу International Taxation - Adnan Islam - Страница 86

Certain amounts received directly or indirectly, for the provision of a guarantee of indebtedness issued after September 27, 2010, are U.S. source income. They must be paid by a noncorporate resident or U.S. corporation or by any foreign person if the amounts are effectively connected with the conduct of a U.S. trade or business. For more information, see Internal Revenue Code Sections 861(a)(9) and 862(a)(9).