U.S. income taxation of nonresident aliens' direct investment in real property rentals

Article Abstract:

Non-resident aliens owning rental property in the US are faced with the tax planning decision of whether or not to classify the income gained as business or personal because of US tax law. Under IRC 871(d), an election can be made which classifies all rental income as business income. This prevents taxation under 871(a) if the rental property fails to meet the test of business or trade income. If the test is met, then the election is superseded by other law. Also, the passive activity loss rules prevent non-resident aliens from filing separately to claim net-operating losses on rentals, business or otherwise.

Lease and rental services industry, Lease and rental services, Non-resident aliens, Nonresident aliens

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India's new investment and tax regime

Article Abstract:

India's government introduced a revised investment and tax policy in 1991, deregulating the economy while stimulating industrial growth and foreign investment. Foreign investors will find the advantageous income tax regime provides strong tax incentives for industrial undertakings. Other tax benefits can be derived from policies on depreciation, dividends, tax-exempt interest, custom and excise duties, sales tax, and technical services' fees and royalties. The deregulated economy features less stringent foreign exchange and price controls, reduced tariffs, and better import-export conditions.

Foreign Investment Regulations, Corporate Income Taxes, Economic aspects, International aspects, Economic policy, India, Deregulation, Taxation, Foreign investment laws

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Confronting tax havens, the offshore phenomenon, and money laundering

Article Abstract:

Offshore facilities and tax havens have become tax evasion vehicles for hiding unreported US income and money-laundering operations. Both US domestic and international corporations have been involved. Advance pricing agreements, tax treaties, tax information exchange agreements, and mutual legal assistance treaties, as well as applicable IRC code sections, have been used to combat the problem. For example, the Treasury's model tax treaty provides for eight information exchange programs. However, the situation is complicated by US privacy and confidentiality protections.

Tax Evasion & Penalties, Regulation of Multi-Nationals, United States, Analysis, Prevention, Multinational corporations, Tax havens, Money laundering, Tax evasion, Tax penalties, International trade regulation, international

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