Tax Analysts contains news, analysis, and commentary on foreign source income. Part III of 26 U.S.C. governs foreign source income for the United States, but Tax Analysts also addresses foreign source income for countries with territorial taxation rather than worldwide taxation. Discussions of corporate, passthrough, individual, citizen, resident, non-resident, and trust foreign source income are all included in Tax Analysts products.
Among the specific topics Tax Analysts covers are inversions; the U.S. foreign earned income exclusion under Internal Revenue Code section 911 (26 U.S.C. 911) and the section 911(a) election; creditability of foreign taxes for U.S. purposes under section 901 (26 U.S.C. 901); foreign tax credit suspension under section 909 (26 U.S.C. 909); taxation of the digital economy; stateless income and income sourcing rules (26 U.S.C. part I, sections 861, 862, 863, 864, 865); withholding rules; allocation and apportionment of expenses between foreign and domestic sources under section 904 (26 U.S.C. 904); the section 906 (26 U.S.C. 906) rules for nonresident aliens and individuals; and the rules under sections 931, 932, 933, 934, 936 on income from U.S. territories and possessions (Guam, American Samoa, Northern Mariana Islands, U.S. Virgin Islands, Puerto Rico).
Tax Analysts covers regulations, legislation, treaties, and court decisions related to foreign source income. See, for example, PPL Corp. et al. v. Commissioner (133 S. Ct. 1897 (2013); commentary; T.D. 9710, 2015-8 IRB 603, news coverage; and Marks & Spencer plc (C-446/03), news coverage.
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