US Taxation of International Shipping, Road Transport & Other Transportation Activity
U.S. Taxation of the U.S. Source Income of Foreign Persons and Companies
International Business

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U.S. Taxation of the U.S. Source Income of Foreign Persons and Companies

Every foreign person or company that receives income from sources within the United States is subject to U.S. tax on that income. In some cases, an income tax treaty between the United States and the country where the foreign person is resident will exempt or reduce the rate of tax payable on that income.

Foreign persons who reside in the United States for more than 183 days a year (or are deemed to have lived in the U.S. for that number of days in any year) are subject to tax in the United States on their worldwide income as if they were U.S. citizens or resident aliens. In some instances, individuals who are in the United States as non-immigrants, for example visiting professors, scientists, and others, may be exempt from U.S. tax on their employment earnings by reason of a tax treaty between their home country and the United States. However, several of the exemptions have conditions that, if not honored, can result in retroactive tax liability.

Foreign companies that earn income from sources in the U.S. are subject to tax on that income unless they are covered by a tax treaty between the United States and the country in which the company is headquartered or organized.

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