Inverworld, Inc., et al. - Page 208

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            Sec. 882(a)(1).  Effectively connected income can originate from                              
            sources within the United States, sec. 864(c)(2) and (3), or from                             
            sources without the United States, sec. 864(c)(4), and is taxed                               
            at the same rates that apply to a U.S. corporation under section                              
            11.  Under the second regime, a flat tax of 30 percent is imposed                             
            on a foreign corporation’s gross income from "interest (other                                 
            than original issue discount as defined in section 1273),                                     
            dividends, rents, salaries, wages, premiums, annuities,                                       
            compensations, remunerations, emoluments, and other fixed or                                  
            determinable annual or periodical gains, profits, and income",                                
            but only to the extent the amount is received from sources within                             
            the United States and is not effectively connected with the                                   
            conduct of trade or business by such corporation within the                                   
            United States.  Sec. 881(a).  A foreign corporation is not                                    
            subject to tax on its income which is not effectively connected                               
            with its conduct of trade or business within the United States                                
            and which is received from sources without the United States.                                 
            Id.  In sum, if LTD is engaged in trade or business within the                                
            United States, income items effectively connected with LTD's                                  
            trade or business, including items from sources without the                                   
            United States as described in section 864(c)(4), are taxed                                    
            pursuant to section 882(a)(1) at regular corporate rates; income                              
            items not effectively connected with any trade or business                                    
            conducted by LTD within the United States, if sourced from within                             






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