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Full-Text Articles in Law
Private And Public Sector Models For Entrepreneur, Small Business Owner, And Investor Immigration Pathways, Shane Dizon
Private And Public Sector Models For Entrepreneur, Small Business Owner, And Investor Immigration Pathways, Shane Dizon
Articles & Chapters
No abstract provided.
The Appellate Body And Harrowsmith Country Life, Sydney M. Cone Iii.
The Appellate Body And Harrowsmith Country Life, Sydney M. Cone Iii.
Articles & Chapters
No abstract provided.
Tax Court Ends The ‘Cascading Royalty’ Problem, Alan Appel
Tax Court Ends The ‘Cascading Royalty’ Problem, Alan Appel
Articles & Chapters
No abstract provided.
Withholding Net Will Now Catch More Debt Arrangements, Alan Appel
Withholding Net Will Now Catch More Debt Arrangements, Alan Appel
Articles & Chapters
When the U.S. terminated its income tax treaty with the Netherlands Antilles in 1984, there was criticism from U.S. corporations that they were being unfairly kept out of the competitive Eurobond financing market. In order to provide access to the Eurobond market, Congress enacted Section 871(h) to provide an exemption (the “portfolio interest exemption”) from the 30% withholding tax on U.S.-source income earned by a nonresident alien individual or foreign corporation that is not effectively connected with the conduct of a U.S. trade or business. Portfolio interest, under Sections 871(h) and 163(f), is any U.S.-source interest (including original issue discount) …