Source of income rules / Ansgar A. Simon, Esq., Covington & Burling LLP, New York, New York.

Arlington, VA : Tax Management, [2007]-

1 online resource.

Updated irregularly.

Tax management portfolios ; 6620.

"Tax Management Portfolio, Source of Income Rules, No. 6620, analyzes the rules for determining the source of income between income from sources within the United States and income from foreign sources. For persons and entities that are not citizens or residents of the United States and not domestic corporations, and that consequently are not subject to U.S. taxation on their worldwide income, the sourcing of income is critical because they are subject to the tax jurisdiction of the United States generally only with respect to income from sources within the United States. In addition, for all persons that are subject to U.S. taxation, the source of income rules are critical for their role in determining the limitation on the availability of a credit for income taxes or taxes in lieu of income taxes paid or accrued to a foreign government. The source of income rules are for this purpose applied in conjunction with the rules governing the allocation and apportionment of expenses to income from U.S. and foreign sources in order to determine foreign-source taxable income in each of the separate foreign tax credit limitation categories under [section] 904."

Authors: Peter H. Blessing and Gregory P. Lubkin, <nov. 15, 2007>.
Previously published as Tax Management portfolio 905-2nd, <nov. 15, 2007>-2019.

Includes bibliographical references.

Description based on contents viewed on August 26, 2020; title from description page.

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Print version: Simon, Ansgar A. Source of income rules. Arlington, VA : Tax Management Inc., ©2019-

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