Page 38 - International Taxation IRS Training Guides
P. 38

Inbound - Jurisdiction to Tax








                                                                                subject to tax only on
              Foreign MNEs are generally

                                                           or the net amount of income that
                   U.S.-source FDAP
                   is effectively connected with a USTB.




              Therefore, sourcing of
                                                                   income (as U.S. vs. foreign) is
                   crucial for Inbound taxpayers.




              Tax treaties
                                             among jurisdictions also assign taxing

                               amongst countries.
                   rights                                                 Therefore, treaties play an

                   enhanced role in the inbound regime.
















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