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FDAP Tax Treaty

Freeman Law

Withholding Agents and FDAP Income

Freeman Law on

Withholding on Foreign Payments of FDAP - Income A withholding agent is generally required to report amounts paid to foreign persons that are subject to non-resident alien withholding. ...more

Freeman Law

FDAP Income

Freeman Law on

The United States generally taxes nonresident aliens and foreign corporations on their U.S.-source income. A foreign taxpayer’s U.S.-source income falls into one of two general categories: (i) “fixed or determinable annual...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

Bilzin Sumberg

Editorial: Qualifying for Treaty Benefits Under the “Derivative Benefits” Article

Bilzin Sumberg on

Foreign persons are subject to U.S. federal income tax on a limited basis. Unlike U.S. persons who are subject to U.S. federal income tax on their worldwide income, foreign persons generally are subject to U.S. taxation on...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

Bilzin Sumberg

Foreign Investment In The U.S. Through Romania Just Became More Interesting

Bilzin Sumberg on

All “modern” income tax treaties concluded by the United States contain a “Limitation on Benefits” (LOB) provision. The purpose of such a provision is to prevent “treaty shopping.” Romania is one of the few remaining...more

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