Читать книгу International Taxation - Adnan Islam - Страница 9

 Investment or passive types of income from U.S. sources (for example, fixed, determinable, annual, or periodical [FDAP]) — Sections 871 and 881

 Effectively connected income (ECI) derived from a U.S. trade or business (ECI from a U.S. trade or business) — based on IRC, U.S. case law, and IRS rulings

 Business profits attributable to a U.S. permanent establishment (PE) — based on U.S. tax treaties and conventions

 Interest expense limitation or the thin capitalization and anti-earnings stripping rules, Section 163(j)

 Debt versus equity U.S. tax law

 Foreign Investment in Real Property Tax Act (FIRPTA) — the disposition of a U.S. real property interest by a foreign person (the transferor) is subject to U.S. source withholding tax. FIRPTA authorized the United States to tax foreign persons on dispositions of U.S. real property interests. Sections 897 and 1445. PATH Act revisions

 Base erosion and anti-abuse tax (BEAT) — Section 59A

 Modified Section 1446(f) and new Section 864(c)(8) reverses the holding within the Grecian Magnesite Mining case, and reverts to the original holding in Rev. Rul. 91-32 for U.S. income tax treatment of foreign partners who sell their interest in an operating U.S. partnership (that is, a U.S. partnership that has ECI from engaging in a U.S. trade or business)