Among other things, they pertained to the determination of when a U.S. person
will be treated as a PFIC shareholder and the taxation of such a shareholder upon the direct, indirect, or deemed receipt of distributions from the PFIC or disposition of the stock of the PFIC.
For example, a foreign independent contractor who performs services in a foreign country for a U.S. person
is not subject to tax withholding or income tax liability in the United States when paid by the U.S.
"(Steele) was approached by an identified U.S. Person
(apparently Fusion GPS' Glenn Simpson), who indicated to Source #1 (Steele) that a U.S.-based law firm (Perkins Coie, which hired Fusion on behalf of the DNC and the Clinton campaign) had hired the identified U.S.
1291 to provide that a U.S. person
who indirectly owns stock of a passive foreign investment company (PFIC) through a tax-exempt organization or account will not be treated as a U.S.
citizen, any other U.S. person
, or anyone known at the time of acquisition to be located within the U.S.
Form 5471--Information Return of U.S. Person
With Respect to Certain Foreign Corporations
The burden placed upon the government to obtain a FISA order is higher if the target is a U.S. person
. (27) The act clearly states that the simple exercise of First Amendment rights by U.S.
For example, failure to provide timely notice to even one U.S. person
required to receive it invalidates the 338(g) election unless the IRS determines that the purchaser made a "good faith" effort to identify and provide timely notice to all required recipients.
Both the International Traffic in Army Regulation (ITAR) (15 CFR 120.15) and the Export Administ ration Regulation (EAR) (15 CFR 772.1) define the term "U.S. person
," although the language of the definitions is not exactly the same.
Contrary to popular belief, there is no absolute ban on intelligence components collecting U.S. person
Generally speaking, a U.S. person
must file an FBAR if he has a financial interest in or signatory or other authority over (in other words, if he owns or can control) any foreign account that has a balance exceeding $10,000 in the aggregate at any point during the year.
956, which may permit the U.S. person
to claim a credit for foreign taxes paid by the CFC to offset the tax generated by the income inclusion.