Tag Archives: U.S. international tax

United States International 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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