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

Resource Information

The work Alternative portfolio income and U.S. income tax treaties : the case of foreign investment in U.S. life insurance policies represents a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation. This resource is a combination of several types including: Work, Language Material, Continuing Resources.

Label

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

Creator

• Daub, P.M

Subject

• beneficial ownership
• foreign investment
• investment income
• life insurance
• treaty benefits

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),

Geographic coverage

North America

Language note

English