"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, . Previously published as Tax Management portfolio 905-2nd, -2019.
Bibliography, etc. Note
Includes bibliographical references.
Formatted Contents Note
Detailed analysis. Introduction Interest income Dividend income Service income Income from use of property rents and royalties Income from the sale of real property Income from the sale of personal property Insurance underwriting income Income from transportation Income from space and ocean activity Income from communications activities Income from certain financial transactions Distributive share of income from certain pass-through entities and S corporations Transactions involving computer programs, digital content, and cloud computing Other income and special rules Working papers.
Source of Description
Description based on contents viewed on August 26, 2020; title from description page.