The Resource Taxation of capital gains to nonresident aliens

Taxation of capital gains to nonresident aliens

Label
Taxation of capital gains to nonresident aliens
Title
Taxation of capital gains to nonresident aliens
Creator
Subject
Language
eng
Summary
FACTS: X is a resident of Foreign Country, but invests heavily in Host Country. Among its investments, X owned stock in ABCCo, a Host Country corporation engaged in a Host Country trade or business, which stock he had purchased several years ago. ABCCo owns a great deal of real estate, which he realised a substantial gain. X also owned 100 percent of the stock of HavenCo, a holding company organised and managed in a low-tax jurisdiction whose only asset was 100 percent of the stock of DEF Corp, a Host Country corporation that operates a Host Country business. X also recently sold all of the HavenCo stock for a substantial gain. X also was a partner in PQR, a partnership engaged in a trade or business in Host Country. X was a passive investor in PQR and recently sold his PQR interest to another individual who was a resident in Host Country. QUESTIONS: 1. (a) What, if any, Host Country tax consequences are there to X on the sale of ABC Stock? (b) If Host Country has an income tax treaty with Foreign Country, will that affect the Host Country tax consequences on the sale? 2. (a) What, if any, Host Country tax consequences are there to X on the sale of HavenCo stock? (b) If Host Country has a tax treaty with either Foreign Country of the country in which HavenCo is resident, will that affect the Host Country tax consequences on the sale? 3. (a) What, if any, Host Country tax consequences are there to X on the sale of his PQR partnership interest? (b) If Host Country has a tax treaty with Foreign Country, will that affect the tax consequences on the sale? 4. Would any of the Host Country tax consequences be different if X was a foreign corporation instead of an individual?
Citation source
In: Tax management international forum. - London. - Vol. 34 (2013),
http://library.link/vocab/creatorName
Messineo, A.E.
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • non-resident alien
  • capital gains tax
  • exemption
  • tax treaty
  • partnership
Label
Taxation of capital gains to nonresident aliens
Instantiates
Publication
Contents
Argentina p. 5-7; Belgium p. 8-11; Brazil p. 12-16; Canada p. 17-20; China p. 21-23; Denmark p. 24-26; France p. 27-32; Germany p. 33-36; India p. 37-41; Ireland p. 42-44; Italy p. 45-49; Japan p. 50-53; Mexico p. 54-55 ; Netherlands p. 56-58; Spain p. 59-63; Switzerland p. 64-70; United Kingdom p. 71-74; United States p. 75-80
Label
Taxation of capital gains to nonresident aliens
Publication
Contents
Argentina p. 5-7; Belgium p. 8-11; Brazil p. 12-16; Canada p. 17-20; China p. 21-23; Denmark p. 24-26; France p. 27-32; Germany p. 33-36; India p. 37-41; Ireland p. 42-44; Italy p. 45-49; Japan p. 50-53; Mexico p. 54-55 ; Netherlands p. 56-58; Spain p. 59-63; Switzerland p. 64-70; United Kingdom p. 71-74; United States p. 75-80

Library Locations

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