The Resource The disparate treatment of non-effectively-connected U.S.-source capital gains realized by nonresident alien individuals present in the United States for more than 182 days in a taxable year : an anomaly in need of repeal

The disparate treatment of non-effectively-connected U.S.-source capital gains realized by nonresident alien individuals present in the United States for more than 182 days in a taxable year : an anomaly in need of repeal

Label
The disparate treatment of non-effectively-connected U.S.-source capital gains realized by nonresident alien individuals present in the United States for more than 182 days in a taxable year : an anomaly in need of repeal
Title
The disparate treatment of non-effectively-connected U.S.-source capital gains realized by nonresident alien individuals present in the United States for more than 182 days in a taxable year : an anomaly in need of repeal
Creator
Subject
Language
eng
Summary
While US citizens and residents are subject to US income tax on their worldwide income, nonresident alien individuals ("NRAs") are generally subject to income tax only on income effectively connected with a US trade or business and on other income that is "fixed or determinable annual or periodical" income derived from sources within the United States. This article examines the US income taxation of NRAs who realize US-source capital gains that are not effectively connected with a US trade or business and describes the limited circumstances where capital gains realized by an NRA are subject to a 30% tax. The article concludes that Congress should consider repealing this tax in light of the inequities it creates and the practical problems with its administration
Citation source
In: Tax management international journal. - Washington. - Vol. 36 (2007),
http://library.link/vocab/creatorName
  • Williamson, D.T
  • Blair Staley, A
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • non-resident alien
  • income tax
  • capital gains
Label
The disparate treatment of non-effectively-connected U.S.-source capital gains realized by nonresident alien individuals present in the United States for more than 182 days in a taxable year : an anomaly in need of repeal
Instantiates
Publication
Label
The disparate treatment of non-effectively-connected U.S.-source capital gains realized by nonresident alien individuals present in the United States for more than 182 days in a taxable year : an anomaly in need of repeal
Publication

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