Tax US here, US there and them here
Need definition of US person and US corporation: Sec. 7701(b)
Need rules to determine the source of income
Interacts w/ substance over form:
suppose US corp gets all Y from foreign source and pays dividend to foreigner: US Y? (See Sec. 861(a)(2))
Interacts with corporate entity rules:
sales among multinational corporations and transfer pricing issues
US owners of foreign investment subsidiaries: the CFC rules
Them here: Special system for non-business income of NRA's
30% flat tax on gross income w/ withholding
US there: problem of coordinating with the territorial host nation
Tax treaties
Foreign earned income allowance: 76K / yr exempt
Tax credit:
offset US tax on foreign income with foreign tax on foreign income