TAX 9869 Lecture Notes - Lecture 49: Withholding Tax, Capital Gain

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17 Jul 2020
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Instead of investing directly, they create a blocker, and then the fp is a partner in the blocker: blocker pays tax and files a us tax return. If this blocker is foreign, then the blocker, in addition to paying 21% tax on ustb, also has to monitor for bp tax. Not be subject to us tax so foreign person owns google stock- living abroad, sells google stock, he will not be subject to us tax: capital gain types of t-actions not subject to us tax. Important exception: (law change after 2017) - when foreign blocker sells us pship, they will have capital gain (if you sell pship, cap gain) In this example, this us pship has a ustb with eci. Irs always of opinion: if foreign corp sells us pship, even though cap gain, if us pship that has ustb, any gain allocated to assets of that.

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