U.S. Portfolio Investment by Foreign Taxpayers
Author : Leonard Schneidman
Publisher :
Page : 336 pages
File Size : 27,56 MB
Release : 1989
Category : Investments, Foreign
ISBN :
Author : Leonard Schneidman
Publisher :
Page : 336 pages
File Size : 27,56 MB
Release : 1989
Category : Investments, Foreign
ISBN :
Author : United States. Congress. House. Committee on Ways and Means
Publisher :
Page : 96 pages
File Size : 21,9 MB
Release : 1990
Category : Double taxation
ISBN :
Author : Thomas St. G. Bissell
Publisher :
Page : pages
File Size : 35,26 MB
Release :
Category : Aliens
ISBN : 9781633593275
Author : United States. Congress. House. Committee on Ways and Means
Publisher :
Page : 186 pages
File Size : 12,83 MB
Release : 1966
Category : Investments, Foreign
ISBN :
Author : Gary Clyde Hufbauer
Publisher : Peterson Institute
Page : 340 pages
File Size : 12,72 MB
Release : 2007
Category : Corporations, Foreign
ISBN : 0881325732
Author : Thomas St. G. Bissell
Publisher :
Page : pages
File Size : 20,33 MB
Release :
Category : Aliens
ISBN : 9781558718807
Author : Peggy B. Musgrave
Publisher :
Page : 204 pages
File Size : 15,24 MB
Release : 1969
Category : Business & Economics
ISBN :
Author : Joosung Jun
Publisher :
Page : 60 pages
File Size : 21,40 MB
Release : 1989
Category : Capital movements
ISBN :
Emphasizes the difference between foreign fixed investment undertaken by the foreign subsidiary and direct investment of the entire international firm, and the need to use different theoretical frameworks in each case.
Author : United States. Congress. Senate. Committee on Finance. Subcommittee on International Finance and Resources
Publisher :
Page : 50 pages
File Size : 19,3 MB
Release : 1976
Category : Government publications
ISBN :
Author : Jeffrey M. Colon
Publisher :
Page : 69 pages
File Size : 30,81 MB
Release : 2016
Category :
ISBN :
The United States is generally a tax haven for foreign portfolio investors: the United States exempts from tax most U.S. source interest and capital gains, but taxes dividends from U.S. companies; tax treaties generally eliminate U.S. tax on interest and reduce the 30% statutory rate on dividends.Foreign investors in U.S. mutual funds have not been treated as favorably. Fund distributions (other than of net capital gains) were originally treated as taxable dividends, regardless of the fund's underlying income. Interest or short-term capital gains earned by the mutual fund -- which would have been tax exempt if directly earned by a foreign investor -- were converted into taxable dividend income when distributed.To encourage foreign investment in U.S. mutual funds, Congress in 2004 modified the mutual fund distribution rules to exempt from tax fund dividends that are attributable to the fund's U.S. source interest income or short-term capital gains. The stated goal of the legislation was to tax foreign investors on the same basis as if they had directly earned their share of a fund's income.These provisions fail to fully achieve this goal by denying pass-through treatment for foreign source interest and dividends. This policy appears to be aimed at preventing foreign investors from using a U.S. mutual fund to obtain U.S. treaty benefits.Foreign source income should retain its source and character when distributed to foreign shareholders. This tax treatment is consistent with the tax results a foreign investor realizes when he or she invests directly or through a partnership and encourages foreign investment in mutual funds that invest globally. The treaty shopping concerns may be illusory. To address potential treaty abuse, Congress could consider limiting the pass- through of foreign source income to treaty residents.