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Tax Return For Students 2011

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Tax Return For Students 2011

Tax return for students 2011 8. Tax return for students 2011   Foreign Insurance Taxes Table of Contents Premium. Tax return for students 2011 Tax is imposed on insurance policies issued by foreign insurers. Tax return for students 2011 Any person who makes, signs, issues, or sells any of the documents and instruments subject to the tax, or for whose use or benefit they are made, signed, issued, or sold, is liable for the tax. Tax return for students 2011 The following tax rates apply to each dollar (or fraction thereof) of the premium paid. Tax return for students 2011 Casualty insurance and indemnity, fidelity, and surety bonds: 4 cents. Tax return for students 2011 For example, on a premium payment of $10. Tax return for students 2011 10, the tax is 44 cents. Tax return for students 2011 Life, sickness, and accident insurance, and annuity contracts: 1 cent. Tax return for students 2011 For example, on a premium payment of $10. Tax return for students 2011 10, the tax is 11 cents. Tax return for students 2011 Reinsurance policies covering any of the taxable contracts described in items (1) and (2): 1 cent. Tax return for students 2011 However, the tax does not apply to casualty insurance premiums paid to foreign insurers for coverage of export goods in transit to foreign destinations. Tax return for students 2011 Premium. Tax return for students 2011   Premium means the agreed price or consideration for assuming and carrying the risk or obligation. Tax return for students 2011 It includes any additional charge or assessment payable under the contract, whether in one sum or installments. Tax return for students 2011 If premiums are refunded, claim the tax paid on those premiums as an overpayment against tax due on other premiums paid or file a claim for refund. Tax return for students 2011 When liability attaches. Tax return for students 2011   The liability for this tax attaches when the premium payment is transferred to the foreign insurer or reinsurer (including transfers to any bank, trust fund, or similar recipient designated by the foreign insurer or reinsurer) or to any nonresident agent, solicitor, or broker. Tax return for students 2011 A person can pay the tax before the liability attaches if the person keeps records consistent with that practice. Tax return for students 2011 Who must file. Tax return for students 2011   The person who pays the premium to the foreign insurer (or to any nonresident person such as a foreign broker) must pay the tax and file the return. Tax return for students 2011 Otherwise, any person who issued or sold the policy, or who is insured under the policy, is required to pay the tax and file the return. Tax return for students 2011    The person liable for this tax must keep accurate records that identify each policy or instrument subject to tax. Tax return for students 2011 These records must clearly establish the type of policy or instrument, the gross premium paid, the identity of the insured and insurer, and the total premium charged. Tax return for students 2011 If the premium is to be paid in installments, the records must also establish the amount and anniversary date of each installment. Tax return for students 2011   The records must be kept at the place of business or other convenient location for at least 3 years after the later of the date any part of the tax became due, or the date any part of the tax was paid. Tax return for students 2011 During this period, the records must be readily accessible to the IRS. Tax return for students 2011   The person having control or possession of a policy or instrument subject to this tax must keep the policy for at least 3 years after the date any part of the tax on it was paid. Tax return for students 2011 For information on reinsurance premiums paid from one foreign insurer to another foreign insurer, see Rev. Tax return for students 2011 Rul. Tax return for students 2011 2008-15. Tax return for students 2011 You can find Rev. Tax return for students 2011 Rul. Tax return for students 2011 2008-15 on page 633 of I. Tax return for students 2011 R. Tax return for students 2011 B. Tax return for students 2011 2008-12 at www. Tax return for students 2011 irs. Tax return for students 2011 gov/pub/irs-irbs/irb08-12. Tax return for students 2011 pdf. Tax return for students 2011 Treaty-based positions under IRC 6114. Tax return for students 2011   You may have to file an annual report disclosing the amount of premiums exempt from United States excise tax as a result of the application of a treaty with the United States that overrides (or otherwise modifies) any provision of the Internal Revenue Code. Tax return for students 2011   Attach any disclosure statement to the first quarter Form 720. Tax return for students 2011 You may be able to use Form 8833, Treaty-Based Return Position Disclosure Under Section 6114 or 7701(b), as a disclosure statement. Tax return for students 2011 See the Instructions for Form 720 for information on how and where to file. Tax return for students 2011   See Revenue Procedure 92-14 in Cumulative Bulletin 1992-1 for procedures you can use to claim a refund of this tax under certain U. Tax return for students 2011 S. Tax return for students 2011 treaties. Tax return for students 2011 Prev  Up  Next   Home   More Online Publications
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SOI Tax Stats - Controlled Foreign Corporations

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  • Data are taken from Form 5471 - Information Return of U.S. Persons With Respect to Certain Foreign Corporations.
  • For U.S. income tax purposes, a foreign corporation is "controlled" if U.S. shareholders own more than 50% of its outstanding voting stock.
  • Data are also available for the One-Time Dividend Received Deduction reported on Form 8895.

Statistical Tables     SOI Bulletin Articles     Metadata   
 


Statistical Tables

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U.S. Corporations and Their Controlled Foreign Corporations
     Data Presented: Number, Assets, Receipts, Earnings, Taxes, Distributions, Subpart F Income, and Related Party Transactions
     Classified by: Selected NAICS Industrial Sector*
     Tax Years: 2008     2006     2004   
 
     Classified by: Selected Country of Incorporation
     Tax Years: 2008     2006     2004   
 
     Classified by: Selected Country of Incorporation and NAICS Industrial Sector*
     Tax Years: 2008     2006     2004   
 
U.S. Corporations with Total Assets of $500 Million or More and Their 7,500 Largest Controlled Foreign Corporations
     Data Presented: Number, Assets, Receipts, Earnings, Taxes, Distributions, and Subpart F Income
     Classified by: Selected NAICS Industrial Sector*
     Tax Years: 2002   2000   1998   1996   1994   1992   1988
 
     Classified by: Selected Country of Incorporation
     Tax Years: 2002   2000   1998   1996   1994   1992   1988
 
     Classified by: Selected Country of Incorporation and NAICS Industrial Sector*
     Tax Years: 2002   2000   1998   1996   1994   1988


 

U.S. Corporations with Total Assets of $500 Million or More and Their 7,500 Largest Controlled Foreign Corporations
     Data Presented: Number, Assets, Receipts, and Earnings, Standard Industrial Classification (SIC) and North American Industry Classification System (NAICS)
     Classified by: Selected NAICS Industrial Sector
     Tax Year: 1998


*Note:  For Tax Years prior to 1998, industry data are presented by Standard Industry Classification (SIC).  Industry data for Tax Years 1998 to present are presented by North American Industry Classification System (NAICS)


SOI Bulletin Articles

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Page Last Reviewed or Updated: 15-Jan-2014

The Tax Return For Students 2011

Tax return for students 2011 2. Tax return for students 2011   Source of Income Table of Contents Introduction Topics - This chapter discusses: Resident Aliens Nonresident AliensInterest Income Dividends Guarantee of Indebtedness Personal Services Transportation Income Scholarships, Grants, Prizes, and Awards Pensions and Annuities Rents or Royalties Real Property Personal Property Community Income Introduction After you have determined your alien status, you must determine the source of your income. Tax return for students 2011 This chapter will help you determine the source of different types of income you may receive during the tax year. Tax return for students 2011 This chapter also discusses special rules for married individuals who are domiciled in a country with community property laws. Tax return for students 2011 Topics - This chapter discusses: Income source rules, and Community income. Tax return for students 2011 Resident Aliens A resident alien's income is generally subject to tax in the same manner as a U. Tax return for students 2011 S. Tax return for students 2011 citizen. Tax return for students 2011 If you are a resident alien, you must report all interest, dividends, wages, or other compensation for services, income from rental property or royalties, and other types of income on your U. Tax return for students 2011 S. Tax return for students 2011 tax return. Tax return for students 2011 You must report these amounts from sources within and outside the United States. Tax return for students 2011 Nonresident Aliens A nonresident alien usually is subject to U. Tax return for students 2011 S. Tax return for students 2011 income tax only on U. Tax return for students 2011 S. Tax return for students 2011 source income. Tax return for students 2011 Under limited circumstances, certain foreign source income is subject to U. Tax return for students 2011 S. Tax return for students 2011 tax. Tax return for students 2011 See Foreign Income in chapter 4. Tax return for students 2011 The general rules for determining U. Tax return for students 2011 S. Tax return for students 2011 source income that apply to most nonresident aliens are shown in Table 2-1. Tax return for students 2011 The following discussions cover the general rules as well as the exceptions to these rules. Tax return for students 2011 Not all items of U. Tax return for students 2011 S. Tax return for students 2011 source income are taxable. Tax return for students 2011 See chapter 3. Tax return for students 2011 Interest Income Generally, U. Tax return for students 2011 S. Tax return for students 2011 source interest income includes the following items. Tax return for students 2011 Interest on bonds, notes, or other interest-bearing obligations of U. Tax return for students 2011 S. Tax return for students 2011 residents or domestic corporations. Tax return for students 2011 Interest paid by a domestic or foreign partnership or foreign corporation engaged in a U. Tax return for students 2011 S. Tax return for students 2011 trade or business at any time during the tax year. Tax return for students 2011 Original issue discount. Tax return for students 2011 Interest from a state, the District of Columbia, or the U. Tax return for students 2011 S. Tax return for students 2011 Government. Tax return for students 2011 The place or manner of payment is immaterial in determining the source of the income. Tax return for students 2011 A substitute interest payment made to the transferor of a security in a securities lending transaction or a sale-repurchase transaction is sourced in the same manner as the interest on the transferred security. Tax return for students 2011 Exceptions. Tax return for students 2011   U. Tax return for students 2011 S. Tax return for students 2011 source interest income does not include the following items. Tax return for students 2011 Interest paid by a resident alien or a domestic corporation on obligations issued before August 10, 2010, if for the 3-year period ending with the close of the payer's tax year preceding the interest payment, at least 80% of the payer's total gross income: Is from sources outside the United States, and Is attributable to the active conduct of a trade or business by the individual or corporation in a foreign country or a U. Tax return for students 2011 S. Tax return for students 2011 possession. Tax return for students 2011 However, the interest will be considered U. Tax return for students 2011 S. Tax return for students 2011 source interest income if either of the following apply. Tax return for students 2011 The recipient of the interest is related to the resident alien or domestic corporation. Tax return for students 2011 See section 954(d)(3) for the definition of related person. Tax return for students 2011 The terms of the obligation are significantly modified after August 9, 2010. Tax return for students 2011 Any extension of the term of the obligation is considered a significant modification. Tax return for students 2011 Interest paid by a foreign branch of a domestic corporation or a domestic partnership on deposits or withdrawable accounts with mutual savings banks, cooperative banks, credit unions, domestic building and loan associations, and other savings institutions chartered and supervised as savings and loan or similar associations under federal or state law if the interest paid or credited can be deducted by the association. Tax return for students 2011 Interest on deposits with a foreign branch of a domestic corporation or domestic partnership, but only if the branch is in the commercial banking business. Tax return for students 2011 Dividends In most cases, dividend income received from domestic corporations is U. Tax return for students 2011 S. Tax return for students 2011 source income. Tax return for students 2011 Dividend income from foreign corporations is usually foreign source income. Tax return for students 2011 Exceptions to both of these rules are discussed below. Tax return for students 2011 A substitute dividend payment made to the transferor of a security in a securities lending transaction or a sale-repurchase transaction is sourced in the same manner as a distribution on the transferred security. Tax return for students 2011 Dividend equivalent payments. Tax return for students 2011   U. Tax return for students 2011 S. Tax return for students 2011 source dividends also include all dividend equivalent payments. Tax return for students 2011 Dividend equivalent payments include substitute dividends, payments made pursuant to a specified notional principal contract, and all similar payments that, directly or indirectly, are contingent on or determined by reference to, the payment of a dividend from U. Tax return for students 2011 S. Tax return for students 2011 sources. Tax return for students 2011    The Internal Revenue Service has issued final regulations that would affect the treatment of dividend equivalent payments and specified notional principal contracts. Tax return for students 2011 You can view this regulation at www. Tax return for students 2011 irs. Tax return for students 2011 gov/irb/2013-52_IRB/ar08. Tax return for students 2011 html. Tax return for students 2011 First exception. Tax return for students 2011   Dividends received from a domestic corporation are not U. Tax return for students 2011 S. Tax return for students 2011 source income if the corporation elects to take the American Samoa economic development credit. Tax return for students 2011 Second exception. Tax return for students 2011   Part of the dividends received from a foreign corporation is U. Tax return for students 2011 S. Tax return for students 2011 source income if 25% or more of its total gross income for the 3-year period ending with the close of its tax year preceding the declaration of dividends was effectively connected with a trade or business in the United States. Tax return for students 2011 If the corporation was formed less than 3 years before the declaration, use its total gross income from the time it was formed. Tax return for students 2011 Determine the part that is U. Tax return for students 2011 S. Tax return for students 2011 source income by multiplying the dividend by the following fraction. Tax return for students 2011   Foreign corporation's gross income connected with a U. Tax return for students 2011 S. Tax return for students 2011 trade or business for the 3-year period     Foreign corporation's gross income from all sources for that period   Guarantee of Indebtedness Certain amounts received directly or indirectly, for the provision of a guarantee of indebtedness issued after September 27, 2010, are U. Tax return for students 2011 S. Tax return for students 2011 source income. Tax return for students 2011 They must be paid by a noncorporate resident or U. Tax return for students 2011 S. Tax return for students 2011 corporation or by any foreign person if the amounts are effectively connected with the conduct of a U. Tax return for students 2011 S. Tax return for students 2011 trade or business. Tax return for students 2011 For more information, see Internal Revenue Code sections 861(a)(9) and 862(a)(9). Tax return for students 2011 Personal Services All wages and any other compensation for services performed in the United States are considered to be from sources in the United States. Tax return for students 2011 The only exceptions to this rule are discussed in chapter 3 under Employees of foreign persons, organizations, or offices, and under Crew members. Tax return for students 2011 If you are an employee and receive compensation for labor or personal services performed both inside and outside the United States, special rules apply in determining the source of the compensation. Tax return for students 2011 Compensation (other than certain fringe benefits) is sourced on a time basis. Tax return for students 2011 Certain fringe benefits (such as housing and education) are sourced on a geographical basis. Tax return for students 2011 Or, you may be permitted to use an alternative basis to determine the source of compensation. Tax return for students 2011 See Alternative Basis , later. Tax return for students 2011 Multi-level marketing. Tax return for students 2011   Certain companies sell products through a multi-level marketing arrangement, such that an upper-tier distributor, who has sponsored a lower-tier distributor, is entitled to a payment from the company based on certain activities of that lower-tier distributor. Tax return for students 2011 Generally, depending on the facts, payments from such multi-level marketing companies to independent (non-employee) distributors (upper-tier distributors) that are based on the sales or purchases of persons whom they have sponsored (lower-tier distributors) constitute income for the performance of personal services in recruiting, training, and supporting the lower-tier distributors. Tax return for students 2011 The source of such income is generally based on where the services of the upper-tier distributor are performed, and may, depending on the facts, be considered multi-year compensation, with the source of income determined over the period to which such compensation is attributable. Tax return for students 2011 Self-employed individuals. Tax return for students 2011   If you are self-employed, you determine the source of compensation for labor or personal services from self-employment on the basis that most correctly reflects the proper source of that income under the facts and circumstances of your particular case. Tax return for students 2011 In many cases, the facts and circumstances will call for an apportionment on a time basis as explained next. Tax return for students 2011 Time Basis Use a time basis to figure your U. Tax return for students 2011 S. Tax return for students 2011 source compensation (other than the fringe benefits discussed later). Tax return for students 2011 Do this by multiplying your total compensation (other than the fringe benefits discussed later) by the following fraction:   Number of days you performed services in the United States during the year     Total number of days you performed services during the year   You can use a unit of time less than a day in the above fraction, if appropriate. Tax return for students 2011 The time period for which the compensation is made does not have to be a year. Tax return for students 2011 Instead, you can use another distinct, separate, and continuous time period if you can establish to the satisfaction of the IRS that this other period is more appropriate. Tax return for students 2011 Example 1. Tax return for students 2011 Christina Brooks, a resident of the Netherlands, worked 240 days for a U. Tax return for students 2011 S. Tax return for students 2011 company during the tax year. Tax return for students 2011 She received $80,000 in compensation. Tax return for students 2011 None of it was for fringe benefits. Tax return for students 2011 Christina performed services in the United States for 60 days and performed services in the Netherlands for 180 days. Tax return for students 2011 Using the time basis for determining the source of compensation, $20,000 ($80,000 × 60/240) is her U. Tax return for students 2011 S. Tax return for students 2011 source income. Tax return for students 2011 Example 2. Tax return for students 2011 Rob Waters, a resident of South Africa, is employed by a corporation. Tax return for students 2011 His annual salary is $100,000. Tax return for students 2011 None of it is for fringe benefits. Tax return for students 2011 During the first quarter of the year he worked entirely within the United States. Tax return for students 2011 On April 1, Rob was transferred to Singapore for the remainder of the year. Tax return for students 2011 Rob is able to establish that the first quarter of the year and the last 3 quarters of the year are two separate, distinct, and continuous periods of time. Tax return for students 2011 Accordingly, $25,000 of Rob's annual salary is attributable to the first quarter of the year (. Tax return for students 2011 25 × $100,000). Tax return for students 2011 All of it is U. Tax return for students 2011 S. Tax return for students 2011 source income because he worked entirely within the United States during that quarter. Tax return for students 2011 The remaining $75,000 is attributable to the last three quarters of the year. Tax return for students 2011 During those quarters, he worked 150 days in Singapore and 30 days in the United States. Tax return for students 2011 His periodic performance of services in the United States did not result in distinct, separate, and continuous periods of time. Tax return for students 2011 Of this $75,000, $12,500 ($75,000 × 30/180) is U. Tax return for students 2011 S. Tax return for students 2011 source income. Tax return for students 2011 Multi-year compensation. Tax return for students 2011   The source of multi-year compensation is generally determined on a time basis over the period to which the compensation is attributable. Tax return for students 2011 Multi-year compensation is compensation that is included in your income in one tax year but that is attributable to a period that includes two or more tax years. Tax return for students 2011   You determine the period to which the compensation is attributable based on the facts and circumstances of your case. Tax return for students 2011 For example, an amount of compensation that specifically relates to a period of time that includes several calendar years is attributable to the entire multi-year period. Tax return for students 2011   The amount of compensation treated as from U. Tax return for students 2011 S. Tax return for students 2011 sources is figured by multiplying the total multi-year compensation by a fraction. Tax return for students 2011 The numerator of the fraction is the number of days (or unit of time less than a day, if appropriate) that you performed labor or personal services in the United States in connection with the project. Tax return for students 2011 The denominator of the fraction is the total number of days (or unit of time less than a day, if appropriate) that you performed labor or personal services in connection with the project. Tax return for students 2011 Geographical Basis Compensation you receive as an employee in the form of the following fringe benefits is sourced on a geographical basis. Tax return for students 2011 Housing. Tax return for students 2011 Education. Tax return for students 2011 Local transportation. Tax return for students 2011 Tax reimbursement. Tax return for students 2011 Hazardous or hardship duty pay as defined in Regulations section 1. Tax return for students 2011 861-4(b)(2)(ii)(D)(5). Tax return for students 2011 Moving expense reimbursement. Tax return for students 2011 The amount of fringe benefits must be reasonable and you must substantiate them by adequate records or by sufficient evidence. Tax return for students 2011 Principal place of work. Tax return for students 2011   The above fringe benefits, except for tax reimbursement and hazardous or hardship duty pay, are sourced based on your principal place of work. Tax return for students 2011 Your principal place of work is usually the place where you spend most of your working time. Tax return for students 2011 This could be your office, plant, store, shop, or other location. Tax return for students 2011 If there is no one place where you spend most of your working time, your main job location is the place where your work is centered, such as where you report for work or are otherwise required to “base” your work. Tax return for students 2011   If you have more than one job at any time, your main job location depends on the facts in each case. Tax return for students 2011 The more important factors to be considered are: The total time you spend at each place, The amount of work you do at each place, and How much money you earn at each place. Tax return for students 2011 Housing. Tax return for students 2011   The source of a housing fringe benefit is determined based on the location of your principal place of work. Tax return for students 2011 A housing fringe benefit includes payments to you or on your behalf (and your family's if your family resides with you) only for the following. Tax return for students 2011 Rent. Tax return for students 2011 Utilities (except telephone charges). Tax return for students 2011 Real and personal property insurance. Tax return for students 2011 Occupancy taxes not deductible under section 164 or 216(a). Tax return for students 2011 Nonrefundable fees for securing a leasehold. Tax return for students 2011 Rental of furniture and accessories. Tax return for students 2011 Household repairs. Tax return for students 2011 Residential parking. Tax return for students 2011 Fair rental value of housing provided in kind by your employer. Tax return for students 2011   A housing fringe benefit does not include: Deductible interest and taxes (including deductible interest and taxes of a tenant-stockholder in a cooperative housing corporation), The cost of buying property, including principal payments on a mortgage, The cost of domestic labor (maids, gardeners, etc. Tax return for students 2011 ), Pay television subscriptions, Improvements and other expenses that increase the value or appreciably prolong the life of property, Purchased furniture or accessories, Depreciation or amortization of property or improvements, The value of meals or lodging that you exclude from gross income, or The value of meals or lodging that you deduct as moving expenses. Tax return for students 2011 Education. Tax return for students 2011   The source of an education fringe benefit for the education expenses of your dependents is determined based on the location of your principal place of work. Tax return for students 2011 An education fringe benefit includes payments only for the following expenses for education at an elementary or secondary school. Tax return for students 2011 Tuition, fees, academic tutoring, special needs services for a special needs student, books, supplies, and other equipment. Tax return for students 2011 Room and board and uniforms that are required or provided by the school in connection with enrollment or attendance. Tax return for students 2011 Local transportation. Tax return for students 2011   The source of a local transportation fringe benefit is determined based on the location of your principal place of work. Tax return for students 2011 Your local transportation fringe benefit is the amount that you receive as compensation for local transportation for you or your spouse or dependents at the location of your principal place of work. Tax return for students 2011 The amount treated as a local transportation fringe benefit is limited to actual expenses incurred for local transportation and the fair rental value of any employer-provided vehicle used predominantly by you, your spouse, or your dependents for local transportation. Tax return for students 2011 Actual expenses do not include the cost (including interest) of any vehicle purchased by you or on your behalf. Tax return for students 2011 Tax reimbursement. Tax return for students 2011   The source of a tax reimbursement fringe benefit is determined based on the location of the jurisdiction that imposed the tax for which you are reimbursed. Tax return for students 2011 Moving expense reimbursement. Tax return for students 2011   The source of a moving expense reimbursement is generally based on the location of your new principal place of work. Tax return for students 2011 However, the source is determined based on the location of your former principal place of work if you provide sufficient evidence that such determination of source is more appropriate under the facts and circumstances of your case. Tax return for students 2011 Sufficient evidence generally requires an agreement between you and your employer, or a written statement of company policy, which is reduced to writing before the move and which is entered into or established to induce you or other employees to move to another country. Tax return for students 2011 The written statement or agreement must state that your employer will reimburse you for moving expenses that you incur to return to your former principal place of work regardless of whether you continue to work for your employer after returning to that location. Tax return for students 2011 It may contain certain conditions upon which the right to reimbursement is determined as long as those conditions set forth standards that are definitely ascertainable and can only be fulfilled prior to, or through completion of, your return move to your former principal place of work. Tax return for students 2011 Alternative Basis If you are an employee, you can determine the source of your compensation under an alternative basis if you establish to the satisfaction of the IRS that, under the facts and circumstances of your case, the alternative basis more properly determines the source of your compensation than the time or geographical basis. Tax return for students 2011 If you use an alternative basis, you must keep (and have available for inspection) records to document why the alternative basis more properly determines the source of your compensation. Tax return for students 2011 Also, if your total compensation from all sources is $250,000 or more, check “Yes” to both questions on line K on page 5 of Form 1040NR, and attach a written statement to your tax return that sets forth all of the following. Tax return for students 2011 Your name and social security number (written across the top of the statement). Tax return for students 2011 The specific compensation income, or the specific fringe benefit, for which you are using the alternative basis. Tax return for students 2011 For each item in (2), the alternative basis of allocation of source used. Tax return for students 2011 For each item in (2), a computation showing how the alternative allocation was computed. Tax return for students 2011 A comparison of the dollar amount of the U. Tax return for students 2011 S. Tax return for students 2011 compensation and foreign compensation sourced under both the alternative basis and the time or geographical basis discussed earlier. Tax return for students 2011 Transportation Income Transportation income is income from the use of a vessel or aircraft or for the performance of services directly related to the use of any vessel or aircraft. Tax return for students 2011 This is true whether the vessel or aircraft is owned, hired, or leased. Tax return for students 2011 The term “vessel or aircraft” includes any container used in connection with a vessel or aircraft. Tax return for students 2011 All income from transportation that begins and ends in the United States is treated as derived from sources in the United States. Tax return for students 2011 If the transportation begins or ends in the United States, 50% of the transportation income is treated as derived from sources in the United States. Tax return for students 2011 For transportation income from personal services, 50% of the income is U. Tax return for students 2011 S. Tax return for students 2011 source income if the transportation is between the United States and a U. Tax return for students 2011 S. Tax return for students 2011 possession. Tax return for students 2011 For nonresident aliens, this only applies to income derived from, or in connection with, an aircraft. Tax return for students 2011 For information on how U. Tax return for students 2011 S. Tax return for students 2011 source transportation income is taxed, see chapter 4. Tax return for students 2011 Scholarships, Grants, Prizes, and Awards Generally, the source of scholarships, fellowship grants, grants, prizes, and awards is the residence of the payer regardless of who actually disburses the funds. Tax return for students 2011 However, see Activities to be performed outside the United States , later. Tax return for students 2011 For example, payments for research or study in the United States made by the United States, a noncorporate U. Tax return for students 2011 S. Tax return for students 2011 resident, or a domestic corporation, are from U. Tax return for students 2011 S. Tax return for students 2011 sources. Tax return for students 2011 Similar payments from a foreign government or foreign corporation are foreign source payments even though the funds may be disbursed through a U. Tax return for students 2011 S. Tax return for students 2011 agent. Tax return for students 2011 Payments made by an entity designated as a public international organization under the International Organizations Immunities Act are from foreign sources. Tax return for students 2011 Activities to be performed outside the United States. Tax return for students 2011   Scholarships, fellowship grants, targeted grants, and achievement awards received by nonresident aliens for activities performed, or to be performed, outside the United States are not U. Tax return for students 2011 S. Tax return for students 2011 source income. Tax return for students 2011    These rules do not apply to amounts paid as salary or other compensation for services. Tax return for students 2011 See Personal Services, earlier, for the source rules that apply. Tax return for students 2011 Pensions and Annuities If you receive a pension from a domestic trust for services performed both in and outside the United States, part of the pension payment is from U. Tax return for students 2011 S. Tax return for students 2011 sources. Tax return for students 2011 That part is the amount attributable to earnings of the pension plan and the employer contributions made for services performed in the United States. Tax return for students 2011 This applies whether the distribution is made under a qualified or nonqualified stock bonus, pension, profit-sharing, or annuity plan (whether or not funded). Tax return for students 2011 If you performed services as an employee of the United States, you may receive a distribution from the U. Tax return for students 2011 S. Tax return for students 2011 Government under a plan, such as the Civil Service Retirement System, that is treated as a qualified pension plan. Tax return for students 2011 Your U. Tax return for students 2011 S. Tax return for students 2011 source income is the otherwise taxable amount of the distribution that is attributable to your total U. Tax return for students 2011 S. Tax return for students 2011 Government basic pay other than tax-exempt pay for services performed outside the United States. Tax return for students 2011 Rents or Royalties Your U. Tax return for students 2011 S. Tax return for students 2011 source income includes rent and royalty income received during the tax year from property located in the United States or from any interest in that property. Tax return for students 2011 U. Tax return for students 2011 S. Tax return for students 2011 source income also includes rents or royalties for the use of, or for the privilege of using, in the United States, intangible property such as patents, copyrights, secret processes and formulas, goodwill, trademarks, franchises, and similar property. Tax return for students 2011 Real Property Real property is land and buildings and generally anything built on, growing on, or attached to land. Tax return for students 2011 Gross income from sources in the United States includes gains, profits, and income from the sale or other disposition of real property located in the United States. Tax return for students 2011 Natural resources. Tax return for students 2011   The income from the sale of products of any farm, mine, oil or gas well, other natural deposit, or timber located in the United States and sold in a foreign country, or located in a foreign country and sold in the United States, is partly from sources in the United States. Tax return for students 2011 For information on determining that part, see section 1. Tax return for students 2011 863-1(b) of the regulations. Tax return for students 2011 Table 2-1. Tax return for students 2011 Summary of Source Rules for Income of Nonresident Aliens Item of income Factor determining source Salaries, wages, other compensation Where services performed Business income:   Personal services Where services performed Sale of inventory—purchased Where sold Sale of inventory—produced Allocation Interest Residence of payer Dividends Whether a U. Tax return for students 2011 S. Tax return for students 2011 or foreign corporation* Rents Location of property Royalties:   Natural resources Location of property Patents, copyrights, etc. Tax return for students 2011 Where property is used Sale of real property Location of property Sale of personal property Seller's tax home (but see Personal Property , later, for exceptions) Pension distributions attributable to contributions Where services were performed that earned the pension Investment earnings on pension contributions Location of pension trust Sale of natural resources Allocation based on fair market value of product at export terminal. Tax return for students 2011 For more information, see section 1. Tax return for students 2011 863-1(b) of the regulations. Tax return for students 2011 *Exceptions include: a) Dividends paid by a U. Tax return for students 2011 S. Tax return for students 2011 corporation are foreign source if the corporation elects the  American Samoa economic development credit. Tax return for students 2011  b) Part of a dividend paid by a foreign corporation is U. Tax return for students 2011 S. Tax return for students 2011 source if at least 25% of the  corporation's gross income is effectively connected with a U. Tax return for students 2011 S. Tax return for students 2011 trade or business for the  3 tax years before the year in which the dividends are declared. Tax return for students 2011 Personal Property Personal property is property, such as machinery, equipment, or furniture, that is not real property. Tax return for students 2011 Gain or loss from the sale or exchange of personal property generally has its source in the United States if you have a tax home in the United States. Tax return for students 2011 If you do not have a tax home in the United States, the gain or loss generally is considered to be from sources outside the United States. Tax return for students 2011 Tax home. Tax return for students 2011   Your tax home is the general area of your main place of business, employment, or post of duty, regardless of where you maintain your family home. Tax return for students 2011 Your tax home is the place where you permanently or indefinitely work as an employee or a self-employed individual. Tax return for students 2011 If you do not have a regular or main place of business because of the nature of your work, then your tax home is the place where you regularly live. Tax return for students 2011 If you do not fit either of these categories, you are considered an itinerant and your tax home is wherever you work. Tax return for students 2011 Inventory property. Tax return for students 2011   Inventory property is personal property that is stock in trade or that is held primarily for sale to customers in the ordinary course of your trade or business. Tax return for students 2011 Income from the sale of inventory that you purchased is sourced where the property is sold. Tax return for students 2011 Generally, this is where title to the property passes to the buyer. Tax return for students 2011 For example, income from the sale of inventory in the United States is U. Tax return for students 2011 S. Tax return for students 2011 source income, whether you purchased it in the United States or in a foreign country. Tax return for students 2011   Income from the sale of inventory property that you produced in the United States and sold outside the United States (or vice versa) is partly from sources in the United States and partly from sources outside the United States. Tax return for students 2011 For information on making this allocation, see section 1. Tax return for students 2011 863-3 of the regulations. Tax return for students 2011   These rules apply even if your tax home is not in the United States. Tax return for students 2011 Depreciable property. Tax return for students 2011   To determine the source of any gain from the sale of depreciable personal property, you must first figure the part of the gain that is not more than the total depreciation adjustments on the property. Tax return for students 2011 You allocate this part of the gain to sources in the United States based on the ratio of U. Tax return for students 2011 S. Tax return for students 2011 depreciation adjustments to total depreciation adjustments. Tax return for students 2011 The rest of this part of the gain is considered to be from sources outside the United States. Tax return for students 2011   For this purpose, “U. Tax return for students 2011 S. Tax return for students 2011 depreciation adjustments” are the depreciation adjustments to the basis of the property that are allowable in figuring taxable income from U. Tax return for students 2011 S. Tax return for students 2011 sources. Tax return for students 2011 However, if the property is used predominantly in the United States during a tax year, all depreciation deductions allowable for that year are treated as U. Tax return for students 2011 S. Tax return for students 2011 depreciation adjustments. Tax return for students 2011 But there are some exceptions for certain transportation, communications, and other property used internationally. Tax return for students 2011   Gain from the sale of depreciable property that is more than the total depreciation adjustments on the property is sourced as if the property were inventory property, as discussed above. Tax return for students 2011   A loss is sourced in the same way as the depreciation deductions were sourced. Tax return for students 2011 However, if the property was used predominantly in the United States, the entire loss reduces U. Tax return for students 2011 S. Tax return for students 2011 source income. Tax return for students 2011   The basis of property usually means the cost (money plus the fair market value of other property or services) of property you acquire. Tax return for students 2011 Depreciation is an amount deducted to recover the cost or other basis of a trade or business asset. Tax return for students 2011 The amount you can deduct depends on the property's cost, when you began using the property, how long it will take to recover your cost, and which depreciation method you use. Tax return for students 2011 A depreciation deduction is any deduction for depreciation or amortization or any other allowable deduction that treats a capital expenditure as a deductible expense. Tax return for students 2011 Intangible property. Tax return for students 2011   Intangible property includes patents, copyrights, secret processes or formulas, goodwill, trademarks, trade names, or other like property. Tax return for students 2011 The gain from the sale of amortizable or depreciable intangible property, up to the previously allowable amortization or depreciation deductions, is sourced in the same way as the original deductions were sourced. Tax return for students 2011 This is the same as the source rule for gain from the sale of depreciable property. Tax return for students 2011 See Depreciable property , earlier, for details on how to apply this rule. Tax return for students 2011   Gain in excess of the amortization or depreciation deductions is sourced in the country where the property is used if the income from the sale is contingent on the productivity, use, or disposition of that property. Tax return for students 2011 If the income is not contingent on the productivity, use, or disposition of the property, the income is sourced according to your tax home as discussed earlier. Tax return for students 2011 If payments for goodwill do not depend on its productivity, use, or disposition, their source is the country in which the goodwill was generated. Tax return for students 2011 Sales through offices or fixed places of business. Tax return for students 2011   Despite any of the earlier rules, if you do not have a tax home in the United States, but you maintain an office or other fixed place of business in the United States, treat the income from any sale of personal property (including inventory property) that is attributable to that office or place of business as U. Tax return for students 2011 S. Tax return for students 2011 source income. Tax return for students 2011 However, this rule does not apply to sales of inventory property for use, disposition, or consumption outside the United States if your office or other fixed place of business outside the United States materially participated in the sale. Tax return for students 2011   If you have a tax home in the United States but maintain an office or other fixed place of business outside the United States, income from sales of personal property, other than inventory, depreciable property, or intangibles, that is attributable to that foreign office or place of business may be treated as U. Tax return for students 2011 S. Tax return for students 2011 source income. Tax return for students 2011 The income is treated as U. Tax return for students 2011 S. Tax return for students 2011 source income if an income tax of less than 10% of the income from the sale is paid to a foreign country. Tax return for students 2011 This rule also applies to losses if the foreign country would have imposed an income tax of less than 10% had the sale resulted in a gain. Tax return for students 2011 Community Income If you are married and you or your spouse is subject to the community property laws of a foreign country, a U. Tax return for students 2011 S. Tax return for students 2011 state, or a U. Tax return for students 2011 S. Tax return for students 2011 possession, you generally must follow those laws to determine the income of yourself and your spouse for U. Tax return for students 2011 S. Tax return for students 2011 tax purposes. Tax return for students 2011 But you must disregard certain community property laws if: Both you and your spouse are nonresident aliens, or One of you is a nonresident alien and the other is a U. Tax return for students 2011 S. Tax return for students 2011 citizen or resident and you do not both choose to be treated as U. Tax return for students 2011 S. Tax return for students 2011 residents as explained in chapter 1. Tax return for students 2011 In these cases, you and your spouse must report community income as explained later. Tax return for students 2011 Earned income. Tax return for students 2011   Earned income of a spouse, other than trade or business income and a partner's distributive share of partnership income, is treated as the income of the spouse whose services produced the income. Tax return for students 2011 That spouse must report all of it on his or her separate return. Tax return for students 2011 Trade or business income. Tax return for students 2011   Trade or business income, other than a partner's distributive share of partnership income, is treated as the income of the spouse carrying on the trade or business. Tax return for students 2011 That spouse must report all of it on his or her separate return. Tax return for students 2011 Partnership income (or loss). Tax return for students 2011   A partner's distributive share of partnership income (or loss) is treated as the income (or loss) of the partner. Tax return for students 2011 The partner must report all of it on his or her separate return. Tax return for students 2011 Separate property income. Tax return for students 2011   Income derived from the separate property of one spouse (and which is not earned income, trade or business income, or partnership distributive share income) is treated as the income of that spouse. Tax return for students 2011 That spouse must report all of it on his or her separate return. Tax return for students 2011 Use the appropriate community property law to determine what is separate property. Tax return for students 2011 Other community income. Tax return for students 2011   All other community income is treated as provided by the applicable community property laws. Tax return for students 2011 Prev  Up  Next   Home   More Online Publications