Source of Income: U.S. Source. vs. Foreign Source.

Description

Non-residents with investments and businesses within the U.S. are generally subject to two taxation alternatives in the U.S.: If they conduct a trade or business within the U.S., a non-resident is considered to have Effectively Connected Income (ECI). On the other hand, if the non-resident receives Fixed, Determinable, Annual, or Periodical (FDAP) income, the non-resident may be subject to a tax withheld at source. This presentation will discuss the various tax implications of ECI and FDAP and the possibilities to reduce withholdings under tax treaties.