U.S. International Tax Guide for Foreign Taxpayers 외국 납세자들을 위한 미국 조세 안내

Preface 04

Part Ⅰ
Background of U.S. International Taxation

Chapter 1 U.S. International Tax System 10
Chapter 2 U.S. Jurisdictional Tax Principles 14
Chapter 3 Sources of U.S. Income Tax Law 20
Chapter 4 Definition of U.S. and Non-U.S. Person 30
Chapter 5 Rules of Income Source and Deduction Allocation 34
Chapter 6 Role of U.S. Income Tax Treaties 39

Part Ⅱ
Filing, Withholding and Reporting Requirements

Chapter 7 Filing Requirements of Non-U.S. Person 44
Chapter 8 Withholding Requirements of Non-U.S. Person 53
Chapter 9 Estate Tax Return Filing Requirements of Non-U.S. Person 61
Chapter 10 Compliance Requirements of Foreign Bank Account Report (FBAR) 66
Chapter 11 Foreign Account Tax Compliance Act (FATCA) Requirements 71

Part Ⅲ
Major Tax Laws Applying for U.S. Activities of Foreign Taxpayers

Chapter 12 IRC Section 482 Allocation 78
Chapter 13 Permanent Establishment (PE) 92
Chapter 14 U.S. Branch Profit Tax 96
Chapter 15 Foreign Tax Credit (FTC) 99
Chapter 16 Foreign Investment in the U.S. Real Property 105
Chapter 17 Earnings Stripping 110

References 116