Background and Issues Relating to the Taxation of Foreign Investment in the United States: Scheduled for Hearings Before the House Committee on Ways and Means on January 24-25 and 30-31, 1990
U.S. Government Printing Office, 1990 - Investments, Foreign - 87 pages
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agent allocation apply argue assets abroad attributable branch profits tax capital gains Code coun deductions determining disposition dividends effectively connected eign enterprise estate and gift example exempt FIRPTA fixed place foreign corporation Foreign Direct Investment foreign investment foreign person foreign tax credit gift tax imposed income tax treaty interest rates International Investment Position international tax investors liabilities loss ment nonresident aliens OECD partnership payments payor percent permanent establishment place of business portfolio investment provides rate of tax real property interest reduce residence country royalties rules shareholders sourced domestically subject to tax tax havens tax policy tax rates tax system taxable income taxpayer tion trade or business transfer pricing Treas treaty country treaty provision treaty shopping U.S. affiliates U.S. assets U.S. branch U.S. business U.S. corporation U.S. dollar U.S. income U.S. persons U.S. real property U.S. tax U.S. taxation U.S. trade United withholding tax worldwide