The Resource Alternative portfolio income and U.S. income tax treaties : the case of foreign investment in U.S. life insurance policies

Alternative portfolio income and U.S. income tax treaties : the case of foreign investment in U.S. life insurance policies

Label
Alternative portfolio income and U.S. income tax treaties : the case of foreign investment in U.S. life insurance policies
Title
Alternative portfolio income and U.S. income tax treaties : the case of foreign investment in U.S. life insurance policies
Creator
Subject
Language
eng
Summary
This article considers the US income tax implications regarding income derived by foreign investors from US risk life settlements and life settlement funds with respect to the death benefit. The first section considers the application of the statutory and regulatory provisions. Then follows an analysis of the types of US income tax provisions under which the death benefit might qualify for exemption. The next section addresses the requirements, both in US treaties and under US internal law, that such income must satisfy in order to qualify for treaty benefits. The analysis concludes with some planning principles
Citation source
In: Tax management international journal. - Arlington. - Vol. 38 (2009),
http://library.link/vocab/creatorName
Daub, P.M
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • foreign investment
  • life insurance
  • treaty benefits
  • investment income
  • beneficial ownership
Label
Alternative portfolio income and U.S. income tax treaties : the case of foreign investment in U.S. life insurance policies
Instantiates
Publication
Label
Alternative portfolio income and U.S. income tax treaties : the case of foreign investment in U.S. life insurance policies
Publication

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