Business Services Industry
The impact of sec. 897 on an NRA or foreign corporation's sale of domestic stock.(nonresident alien individuals)
Tax Adviser, The, November, 2007 by Calianno, Joseph M.; Petersen, Kagney
Foreign corporations and nonresident alien individuals (NRAs) frequently invest in the United States via the stock of domestic corporations. When they make such an investment, in addition to considering the U.S. international tax implications of distributions from such entities, they must also consider the U.S. federal tax implications of a subsequent disposition of their interest in a domestic corporation. (1) Subject to certain exceptions, an NRA or foreign corporation's taxable sale of its domestic corporation stock normally results in a foreign source gain or loss under Sec. 865(a) that is not subject to U.S. taxation. (2)
One of the notable exceptions to this general rule, however, occurs when the domestic corporation's stock is stock of a U.S. real...
Most Recent Business Articles
- Multiple criteria evaluation and optimization of transportation systems
- Multi-criteria analysis procedure for sustainable mobility evaluation in urban areas
- A two-leveled multi-objective symbiotic evolutionary algorithm for the hub and spoke location problem
- Multi-criteria analysis for evaluating the impacts of intelligent speed adaptation
- The development of Taiwan arterial traffic-adaptive signal control system and its field test: a Taiwan experience
Most Recent Business Publications
Most Popular Business Articles
- 7 tips for effective listening: productive listening does not occur naturally. It requires hard work and practice - Back To Basics - effective listening is a crucial skill for internal auditors
- FAS 109: a primer for non-accountants - Financial Accounting Standards Board's "Statement 109: Accounting for Income Taxes"
- LIFO vs. FIFO: a return to the basics
- Too Young to Rent a Car? - 25-years-old the minimum age for car renting - Brief Article
- Design a commission plan that drives sales - Sales Commissions
