Category Archives: International Tax

Taxation of Foreign Nongrantor Trusts: Throwback Rule

Posted on August 4, 2014 by David L. Silverman, J.D., LL.M. (Taxation)

I. Introduction  The throwback rule is intended to prevent a foreign trust from accumulating income, thereby delaying the reporting of that income by U.S. beneficiaries until the time when the income is eventually distributed. The throwback rules defeat this income … Continue reading →

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United States International Taxation

Posted on March 15, 2010 by David L. Silverman, J.D., LL.M. (Taxation)

The U.S. international income tax rules are among the most complex in the Code. The purpose of this article will be to set forth in a comprehensible manner the essence of those rules. Part I will discuss how a foreign person may become subject to U.S. tax, and the distinction between foreign and domestic “source” income. Part I will also introduce the concept of income “effectively connected” with a “U.S. trade or business.” Part II, appearing in the next issue, will conclude a discussion of the trade or business concept, and will discuss the foreign tax credit, the impact of treaties, and other issues. Continue reading →

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