Background And Issues Relating to the Taxation of Foreign Investment in the United States : Scheduled for Hearings Before the House Committee On Ways And Means On January 24-25 And 30-31, 1990 Jcs-1-90
Background And Issues Relating to the Taxation of Foreign Investment in the United States : Scheduled for Hearings Before the House Committee On Ways And Means On January 24-25 And 30-31, 1990 Jcs-1-90
United States. Congress. Joint Committee On Taxation
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871(d) and 882(d)). The Code provides certain exceptions to the general 30-percent tax on gross income. A percentage of each dividend paid by a do- mestic corporation, 80 percent or more of the relevant income of which is active foreign business income, is exempt from tax (sees. 871(i)(2)(B) and 881(d)). In addition, certain investment income re- ceived by foreign governments is exempt from U.S. income tax (see. 892). The types of income which are granted this exemption include the income recei...ved from investments in the United States in stocks, bonds, or other domestic securities, investments in the United States in financial instruments held in the execution of gov- ernmental financial or monetary policy, and interest on deposits in banks in the United States of moneys belonging to a foreign gov- ernment. The exemption does not apply to income attributable to a commercial activity conducted by a foreign government. A similar exemption applies to investment income earned in the United States by international organizations.
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