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Policy Issues Relating To The U.S. Taxation Of Foreign Persons Engaged In Business In The United States Through Agents: Some Proposals For Reform, Richard Crawford Pugh

San Diego International Law Journal

This Article will begin by discussing the circumstances under which a foreign person will be deemed to be engaged in a trade or business in the United States and by examining a proposal that would introduce a great level of certainty for tax planners and the IRS. The principal focus of the Article, however, will be on the circumstances under which the United States should impose U.S. income tax on the income of a foreign person from a business conducted, not directly in the United States, but through an agent acting on behalf of the foreign person. The treatment of …

Addressing Inequities In The Collection Of Social Security Taxes For U.S. Citizens Working Abroad

San Diego Law Review

Social Security and Medicare taxes are imposed on employee wages and self-employment earnings prior to retirement. One half of the tax is. paid by the employer and one half by the employee, with the employer's portion being paid out of the general funds of the business and the

employee's portion being subtracted from her wages. With a self- employed individual, the outcome changes. The totality of the tax

remains the same; however, the self-employed individual assumes responsibility for both halves of the Social Security and Medicare taxes!

The same amount of tax is paid, but it is paid completely by …