Article VI(1) limited United States source taxation of portfolio dividends to 15 per cent and limited United States taxation
of non-portfolio dividends (in relation to holdings of 95 per cent or more) to five per cent.
74) Foreign individuals exempt from United States taxation under treaty threshold rules for personal services may be exempt from United States social security contribution requirements under these provisions in a few tax treaties.
113) Under these treaties, residents of these countries are not subject to United States taxation on United States benefits they receive.
117) The United States employs the saving clause to prevent its citizens from establishing foreign residency and using a treaty to achieve reduced United States taxation on United States-source income.
Under saving clause provisions, it is possible for a person who becomes a resident of another contracting state to be subject to United States taxation, including social security taxation, as if the person was a current United States citizen or resident.
However, an exception applies "to any amount that is income of a related foreign person with respect to which the related foreign person is exempt from United States taxation
on the amount owed pursuant to a treaty obligation of the United States," except for interest.
To settle this dispute, GATT established a Panel to examine the effects of DISCs on United States taxation.
164) Because foreign trade income was treated as foreign source income not effectively connected to the parent corporation, it was not subjected to United States taxation.
217) Any income considered ETI is excluded from gross income, thus avoiding United States taxation.
The Journal of International Taxation provides in-depth coverage of United States taxation
issues relating to international transactions as well as foreign taxation matters.
United States Taxation
of Foreign Investors An overview and introduction to federal tax laws as they apply to foreign corporations and foreign investors.