Page 272 - International Taxation IRS Training Guides

How Can GTOC Analysis
Help? (Cont’d)

(Cont’d)
Proper labeling is important!

 Determine jurisdiction/country

important to properly diagram and label the entities
• It i s
the reader can determine jurisdiction of income
so that
liability and to determine jurisdiction for sourcing of
tax
income

– Country of
incorporation
– Country of
taxing jurisdiction
management and control
– Source country of

entity classification
 Determine proper US

• In order
to determine the proper US income tax results,
it i s
often helpful to explain the US entity classification
income tax treatment of the
and the associated US
transaction on the diagram

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