Page 42 - International Taxation IRS Training Guides

Inbound - Jurisdiction to Tax:

U.S.
Trade or Bus/Perm Establishment

 USTB

the IRC, an FC engaged in a “U.S. trade or business”
• Under
(through a branch or
partnership) is taxed on its ECI.

• It may also be subjected to the “branch profits tax.”
a partnership, U.S. withholding tax may be required.
• If i t i s

 PE

• If a tax treaty applies between the countries, these rules are a
little
different.
treaties serve to establish who has primary jurisdiction to
• Tax
tax
the income.

treaties also specify how certain income types will be
• Tax
what rates.
taxed and at

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