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This chapter include objectives: Understand the basic U.S. framework for taxing multinational transactions and the role of the foreign tax credit limitation, apply the U.S. source rules for common items of gross income and deductions, recall the role of income tax treaties in international tax planning,. | Chapter 24 The U.S. Taxation of Multinational Transactions Learning Objectives Understand the basic U.S. framework for taxing multinational transactions and the role of the foreign tax credit limitation Apply the U.S. source rules for common items of gross income and deductions Recall the role of income tax treaties in international tax planning Identify creditable foreign taxes and compute the foreign tax credit limitation Distinguish between the different forms of doing business outside the United States and list their advantages and disadvantages Comprehend the basic U.S. anti-deferral tax regime and identify common sources of subpart F income U.S. Framework for Taxing Multinational Transactions The U.S. taxes citizens and residents on their worldwide income and nonresidents on their U.S. source income. The criteria chosen by a government to assert its right to tax a person or transaction is called nexus. U.S. Framework for Taxing Multinational Transactions Source-based . | Chapter 24 The U.S. Taxation of Multinational Transactions Learning Objectives Understand the basic U.S. framework for taxing multinational transactions and the role of the foreign tax credit limitation Apply the U.S. source rules for common items of gross income and deductions Recall the role of income tax treaties in international tax planning Identify creditable foreign taxes and compute the foreign tax credit limitation Distinguish between the different forms of doing business outside the United States and list their advantages and disadvantages Comprehend the basic U.S. anti-deferral tax regime and identify common sources of subpart F income U.S. Framework for Taxing Multinational Transactions The U.S. taxes citizens and residents on their worldwide income and nonresidents on their U.S. source income. The criteria chosen by a government to assert its right to tax a person or transaction is called nexus. U.S. Framework for Taxing Multinational Transactions Source-based jurisdiction The United States taxes only the U.S. source income of non-U.S. resident individuals and corporations. Residence-based jurisdiction The United States taxes the worldwide income of U.S. citizens and residents (individuals and corporations). Primary jurisdiction U.S. source income Residual jurisdiction non-U.S. source income U.S. Framework for Taxing Multinational Transaction U.S. Taxation of a Nonresident U.S. source income earned by a nonresident is classified into two categories Effectively connected income (ECI) Taxed on a net basis using the U.S. graduated tax rates Fixed and determinable, annual or periodic Income (FDAP) Taxed on a gross basis through a flat withholding tax U.S. Framework for Taxing Multinational Transaction Definition of a resident for U.S. tax purposes A noncitizen is treated as a U.S. resident alien for income tax purposes if the individual is a permanent resident (has a green card) or meets a substantial presence test. Substantial presence test The .
