Inverworld, Inc., et al. - Page 102

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            pursuant to section 1441(a).  However, interest that is treated                               
            as income from sources without the United States is not subject                               
            to withholding tax pursuant to section 1.1441-1, Income Tax                                   
            Regs., or, therefore, section 1.1442-1, Income Tax Regs.  Sec.                                
            1.1441-3(a), Income Tax Regs.  Additionally, no tax is required                               
            to be deducted and withheld pursuant to section 1441(a) from any                              
            amount described in section 871(i)(2).  Secs. 1441(c)(10),                                    
            1442(a).                                                                                      
                  3.    Withholding Tax on Dividends                                                      
                        a.     Character and Source Rules                                                 
                               for Dividends                                                              
                  Dividend payments made before December 31, 1986, will be                                
            treated as income from sources within the United States if the                                
            amount received as dividends is:                                                              
                  from a foreign corporation unless less than 50 percent                                  
                  of the gross income from all sources of such foreign                                    
                  corporation for the 3-year period ending with the close                                 
                  of its taxable year preceding the declaration of such                                   
                  dividends (or for such part of such period as the                                       
                  corporation has been in existence) was effectively                                      
                  connected with the conduct of a trade or business                                       
                  within the United States; but only in an amount which                                   
                  bears the same ratio to such dividends as the gross                                     
                  income of the corporation for such period which was                                     
                  effectively connected with the conduct of a trade or                                    
                  business within the United States bears to its gross                                    
                  income from all sources * * *  [Sec. 861(a)(2)(B).]                                     
                               b.    Taxation of Dividends                                                
                  Section 871(a)(1) imposes on a nonresident alien individual                             
            a tax of 30 percent of the amount of dividends treated as income                              
            from sources within the United States, if the amount of dividends                             






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