The Resource Guarantee fees : where are we now?

Guarantee fees : where are we now?

Label
Guarantee fees : where are we now?
Title
Guarantee fees : where are we now?
Creator
Subject
Language
eng
Summary
For many years, the proper sourcing of guarantee fees has been controversial. Whether a guarantee fee is U.S. or foreign sourced is important for withholding tax and foreign tax credit purposes as well as for other purposes under the Code. IRS has usually asserted that guarantee fees should be sourced, by analogy, like interest, but characterized them as "other income" for treaty purposes, while some taxpayers have claimed that the fees are more analogous to service fees sourced based on where the services are performed
Citation source
In: Journal of international taxation. - New York. - Vol. 27 (2016), no. 9 ; p. 26-35, 60-63
http://library.link/vocab/creatorName
  • Naughton, L.F
  • Villano, G
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • guarantee fee
  • source of income
  • income classification
  • services
  • tax treaty
Label
Guarantee fees : where are we now?
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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