The branch profits tax was implemented to subject the income earned by foreign corporations operating in the United States to two levels of taxation like income […]
INCOME FROM MIXED SOURCES Some income may have multiple sources. The rule varies according to the type of income-producing asset. INVENTORY SALES: GENERAL RULES There are […]
Regulation § 1.6012-2(g)(1) requires foreign corporations that are viewed under the IRC to be engaged in ongoing U.S. trade or business activity to file Form 1120-F […]
In limited circumstances, U.S. tax attributes are affected by the actions of foreign persons with no immediate physical presence in the United States. Consider the following […]
