AFM463 Lecture Notes - Lecture 4: Foreign Corporation, Passive Income, Withholding Tax
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27 Dec 2019
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Employment income: compensation for labor performed in the u. s. is considered income from u. s. sources . Unless all parts of the following exception is met: (a) (b) (c) Labor is by a non-resident temporarily present in the u. s. for a period or periods not exceeding a total of 90 days during the taxation years. Such compensation does not exceed ,000 in the aggregate. The compensation is for labor performed for (i) A non-resident alien, foreign partnership, or foreign corporation not engaged in trade of business within the u. s. , or. An individual who is a citizen or resident of the u. s. , a domestic partnership or corporation whose office is in a foreign country (ii) U. s. sourced wages: total compensation * u. s. workdays / total workdays. Bonuses: sourced based on workdays in year the bonus was earned (not paid). Stock options: sourced based on the applicable period, which is the period between grant and the date the option becomes exercisable (vesting date).
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