外籍居民。
However, the exemption is subject to the condition that the participated company is not a resident of a state or territory that has a privileged tax regime for Controlled Foreign Companies (CFC) purposes (see Taxation of Resident Companies – Controlled Foreign Company (CFC) Rules). 但是，免税仅...
A client could be considered a U.S. resident for tax purposes by virtue of the time spent in the U.S. according to the substantial presence test. The test must be applied each year that the individual is in the United States. Students (F1, OPT, J1, Q Visas) are considered non-resid...
For tax purposes, if you are not a citizen of the U.S., theInternal Revenue Service (IRS)will consider you either a resident alien or a nonresident alien. You are a resident alien of the U.S. for tax purposes if you meet either the green card test or the substantial presence test f...
A resident alien is an individual who is not a U.S. citizen but is considered a resident of the U.S. for tax purposes. Resident aliens are subject to U.S. federal income tax on their worldwide income, similar to U.S. citizens. ...
This threshold is higher for married couples filing jointly and individuals living abroad. Resident aliens for tax purposes face the same reporting requirements as U.S. citizens. Nonresident aliens may have FATCA obligations if they hold U.S. assets or receive U.S. source income. Individuals ...
Capital gains and foreign resident beneficiaries: The tax treatment of capital gains distributed by a discretionary trust to a foreign resident is at the forefront of recent guidance by the Commissioner Taxation in AustraliaJones, Daryl
"HTJ.TAX Podcast" ( HTJ Podcast) How do I become tax resident of a foreign country (Podcast Episode 2021) - Plot summary, synopsis, and more...
Approach: under this approach, a country identifies certain countries as low-tax countries for purposes of applying its CFC rules to CFCs resident in those countries.Global Approach: An approach for applying CFC rules under which the CFC rules apply to CFCs whether or not they set in tax ...
They must have a permanent establishment in Vietnam or must be a resident for tax purposes. The execution of the project/contract in Vietnam lasts for 183 days or more, calculated from the effective date of the project/contract. They adopt thefullVAS, apply for tax registration, and obtain...