Improper Use of Foreign Addresses to Evade U.S. Taxes: Hearing Before a Subcommittee of the Committee on Government Operations, House of Representatives, Ninety-seventh Congress, Second Session, June 10, 1982U.S. Government Printing Office, 1982 - 383 pages |
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Common terms and phrases
30 percent amount of tax ANNUITIES apply banks bill CALENDAR YEAR 1900 certification COMPENSATION FOR INDEPENDENT compliance COPYRIGHT ROYALTIES COUNTRY CODE COUNTRY OF RESIDENCE deposits DIVIDENDS PAID employer identification estimated exemption filed foreign addresses foreign persons GRANWELL GROSS AMOUNT gross income identify INCOME AND NATURAL income paid income tax INDEPENDENT PERSONAL SERVICES information reporting interest income INTEREST PAID Internal Audit Internal Revenue Code Internal Revenue Service liability million NATURAL RESOURCES ROYALTIES Netherlands Antilles nominee accounts NONRESIDENT ALIEN NONRESIDENT ALIEN INCOME obligations PAID BY U.S. paid to foreign partnership penalty procedures REAL PROPERTY REAL PROPERTY INCOME reduced rates reduced treaty rates reduced withholding refund system REPORTED ON FORM ROSENTHAL Section 861 Swiss Switzerland system of withholding tax haven tax return tax treaty TAX WITHHELD taxable trade or business Treasury treaty benefits treaty partners TYPE OF INCOME U.S. taxpayers United Kingdom WITHHELD AS REPORTED withholding rates withholding tax
Popular passages
Page 314 - For purposes of this chapter, the term "employment" means * * * any service, of whatever nature, performed * * * by an employee for the person employing him * * * except — ***** (18) Service which is performed by a nonresident alien individual for the period he is temporarily present in the United States as a nonimmigrant under subparagraph (F) or (J) of section 101 (a) (15) of the Immigration and Nationality Act (as amended, and which is performed to carry out the purpose specified in subparagraph...
Page 317 - ... (B) from a foreign corporation unless less than 50 percent of the gross income of such foreign corporation for the 3-year period ending with the close of its taxable year preceding the declaration of such dividends (or for such part of such period as the corporation has been in existence) was derived from sources within the United States...
Page 313 - All persons, in whatever capacity acting, including lessees or mortgagors of real or personal property, fiduciaries, employers, and all officers and employees of the United States, having the control...
Page 316 - United States. The following items of gross income shall be treated as income from sources without the United States...
Page 318 - States as determined under the provisions of this part; but only in an amount which bears the same ratio to such dividends as the gross income of the corporation for such period derived from sources within the United States bears to Its gross income from all sources; but dividends from a foreign corporation shall, for...
Page 197 - Chairman Subcommittee on Commerce, Consumer, and Monetary Affairs Committee on Government Operations House of Representatives Washington, DC 20515 Dear Mr.
Page 317 - ... unless less than 50 percent of the gross income from all sources of such foreign corporation for the 3-year period ending with the close of its taxable year preceding the declaration of such dividends (or for such part of such period as the corporation has been in existence) was effectively connected with the conduct of a trade or business within the United States...
Page 318 - Dividends received by corporations — (a) General rule. In the case of a corporation, there shall be allowed as a deduction an amount equal to the following percentages of the amount received as dividends from a domestic corporation which is subject to taxation under this chapter...
Page 313 - ... rent, salaries, wages, premiums, annuities, compensations, remunerations, emoluments, or other fixed or determinable gains, profits, and income...
Page 317 - Interest on deposits with a foreign branch of a domestic corporation or a domestic partnership, if such branch is engaged in the commercial banking business...