Attractive Enough To Be Forced?: The Implications Of The Force Of Attraction Rule For Certain Credit Funds

Authors :: Pae, JoonBeom
Source :: Mondaq Business Briefing. August 20, 2024
Publication Year :: 2024
Abstract: The question of whether a foreign person's income would be treated as income 'effectively connected' with a trade or business in the United States ('ECI') often invites significant confusion and [...]

Subjects :: Tax law -- Interpretation and construction
Foreign source income taxation -- Laws, regulations and rules
Tax administration and procedure -- Laws, regulations and rules
Government regulation
Tax law
Business, international
Internal Revenue Code

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