Attached is an article that I co-authored with Randall Brody, EA of Tax Samaritan that appeared in the November-December 2016 issue of “EA Journal.”
Non-U.S. persons must pay U.S. tax on certain kinds of income they receive from U.S. sources. Typically, the income is taxed at a flat rate of
After the IRS shouted “Dracarys” in 2010, the Foreign Account Tax Compliance Act (FATCA) breathed fire on American taxpayers, causing more chaos than the destruction
The Problem A double taxation problem arises when a taxpayer who has a personal relationship with one country (home country) derives income from sources within
a. Purpose of Limitation The purpose of the foreign tax credit limitation is to confine the effects of the credit to mitigating double taxation of
The U.S. taxes U.S. persons on all of their income, regardless of its source. This creates a double taxation problem with respect to a U.S.
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