Tag: International Tax Law
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Legal Entity
Legal Entity means:a person or organization that has the legal standing to enter into a contract and may be sued for failure to perform as agreed in the contract. Generally, corporations, joint-stock companies and limited liability companies are regarded for tax purposes as having an existence s…
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Foreign-source Income
About Foreign-source Income: gross income from sources outside the United States.U.S. and other Developed Countries International Tax MeaningGenerally income realized from countries outside the country of residence of the taxpayer….
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Substantial Presence Test
Substantial Presence Test means:a test to determine U.S. residency (in the United States, since the test is used to determine residence status, in other countries, based on the number of days, months, etc. of physical presence within a country. A resident alien is a U.S. resident for backup with…
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Minimum Tax
About Minimum Tax: In certain countries or jurisdictions, companies or corporations are always liable to a certain amount of annual tax, regardless of whether they have realized a profit. See alternative minimum tax….
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Creditor
Creditor means:a person (individual or entity) who has extended credit and to whom money is owed; a lender. Contrast debtor….
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Dual Resident
Dual Resident means:a taxpayer who is a resident of two countries. Most U.S. tax treaties with other countries contain a “tiebreaker” provision that determines the country of residence of a person who is a resident of both countries.U.S. and other Developed Countries International Tax Meanin…
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Turnover Tax
About Turnover Tax: General term used to refer to the different forms of consumption and sales taxes. Turnover is the volume of business of an enterprise as set forth in the profit and loss account. It is usually measured by reference to the gross receipts, or gross amounts due, from the sale of goo…
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Expatriate
Expatriate means:a nonresident alien who lost U.S. citizenship within the 10-year period preceding the close of the tax year and had as one of his or her principal purposes the avoidance of taxes. Persons who have left their country and live abroad. The expatriate is still subject to U.S. taxati…
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Comparable Uncontrolled Price Method
About Comparable Uncontrolled Price Method: Comparable Uncontrolled Price (CUP) Method is one of five methods for determining an arm's-length price for tangible property transfers. A transfer pricing method that compares the price for property or services transferred in a controlled transaction to t…
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Global Hedging
Global Hedging means:a risk-management strategy to balance positions of different business units or with unrelated third parties. An exception to mark-to-market rules is provided for global hedging.U.S. and other Developed Countries International Tax MeaningGLOBAL HEDGING – A risk-manag…