Over the last five years for which data are available, the number of foreign corporations showing net income on Form 1120F, U.S. Income Tax Return of a Foreign Corporation, has increased 36.5 percent.  In addition, the number of individuals granted temporary stays in the United States as non-immigrants has steadily increased from 9.5 million in 1985 to 24.8 million in 1996, an average annual increase of 9.1 percent.  These increases evidence growing opportunities to serve international clients and suggest that tax professionals must have a fundamental working knowledge of the way the U.S. tax system treats foreign parties.  This article analyzes the basic provisions for tax professionals who wish to obtain such knowledge and highlights tax planning opportunities.
Larkins, Ernest R.
"U.S. Income Taxation of Foreign Parties: A Primer,"
Syracuse Journal of International Law and Commerce: Vol. 26:
1, Article 3.
Available at: https://surface.syr.edu/jilc/vol26/iss1/3
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