Passive Foreign Investment Company (PFIC) A foreign entity/form of investment is a PFIC if it meets either the income or asset test described below. Income test. 75% or more of the corporation’s gross income for its taxable year is passive income (as defined in...
The Supreme Court reprimands the Spanish Tax Agency (AEAT) for skipping double taxation agreements. It points out that what these agreements establish prevails over national legislation. The Supreme Court puts the Tax Administration in its place for unilaterally...
An investigation has shown that the IRS has fallen far short of its goals in implementing the FATCA legislation. With stricter requirements, the department hopes to detect non-compliance more quickly by U.S. Citizens living and working abroad. The U.S. Tax system,...
All U.S. and Spanish Treaties to Avoid Double Taxation What is all about treaties or other agreements that regulate taxation. In this document we have tried to gather all the treaties and agreements that Spain has signed with different countries or entities that may...
Overview The origins of the US tax laws begin with the Sixteenth Amendment of the United States Constitution. Historically, the U.S. government had relied on tariffs as a source of revenue since the country saw income taxes as controversial at that time. Congress had...
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