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Corporate Taxes › Internal Revenue Service › FDAP

Freeman Law

Effectively Connected Income

Freeman Law on

Effectively Connected Income - Unlike FDAP income, the United States taxes effectively connected income (“ECI”) on a net basis. Effectively connected income is income that is effectively connected with the conduct of a U.S....more

Troutman Pepper

Tax Planning for Investment Into the United States Through Hybrid Entities - Tax Update Volume 2017, Issue 4

Troutman Pepper on

The Tax Section of the New York State Bar Association recently issued a report commenting on the appropriate application of treaty limitations to source-country taxation of business profits when the underlying income is...more

A&O Shearman

The US Tax Court Rejects IRS Position That Non-US Partners Are Taxed on Sales of Partnership Interests

A&O Shearman on

The US Tax Court earlier this month issued a decision that rejected a 25-year old IRS Revenue Ruling and held that gain from the sale or other disposition by a non-US person of an interest in a partnership that is engaged in...more

Bilzin Sumberg

Statutory Exemption from U.S. Withholding Tax on Dividends Remains

Bilzin Sumberg on

Generally, a non-U.S. taxpayer that is not engaged in a U.S. trade or business is taxable in the United States only on U.S.-source “fixed determinable, annual or periodical” income (FDAP)....more

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