U.S. Tax Aspects of Doing Business Abroad |
Contents
Introduction | 1 |
Choice of Entity | 11 |
Choice of Country | 27 |
Copyright | |
21 other sections not shown
Common terms and phrases
988 transaction activities adjusted basis allocated amount apply apportioned attributable capital gain computed Contracting controlled corporation's December 31 deduction deemed determined DISC distribution dividend domestic corporation earnings and profits effectively connected eign election entity example exempt fair market value filed foreign base company foreign corporation foreign country foreign income foreign person foreign resident foreign tax credit FPHC income functional currency gain or loss gross income gross receipts income tax Independent personal services intangible property interest expense investment liabilities method nonresident alien partnership passive income payment PFIC purposes qualified received resident No limit section 482 subpart F income tax rate tax return tax treaty taxable income taxation Temp tion trade or business transaction transfer Treas treated U.S. assets U.S. citizen U.S. corporation U.S. dollars U.S. person U.S. real property U.S. shareholders U.S. tax U.S. trade United USCo USRPI withholding tax