Friday, April 10, 2015

US International Tax Framework 1 - Territorial vs. Worldwide tax system

This is my first ever posting!! I am very excited to share my knowledge with those who want to learn more about U.S. International Tax.

Before we explore U.S. taxing system related to cross-border activities, let’s take a look at two basic regimes of income taxation: territorial and worldwide.

In territorial taxation the taxing country taxes only income arising within it, regardless of the residence or nationality. It is also known as “source-based” taxation system.

In worldwide taxation the taxing country taxes the entire income from all sources of a class of persons (individuals and entities) connected to it, generally by nationality or residence. It is also known as “residence-based” taxation system. US is the classic example of worldwide tax system.

Wait a minute!! US has worldwide tax system, which imposes tax on the worldwide income of US citizens, US residents, and entities. This means non-US resident can earn free money in the US?!!!!

Nice try. Unfortunately, that is not the case.

US uses a “hybrid” taxing system, which applies worldwide tax system to US persons (individuals and entities) and applies territorial system to non-US persons.

So if you are a US person, you pay taxes to US government even though you didn’t step a foot in US land. This might cause double taxation, which means you pay tax twice (US and foreign country) on the same income. This is not good, right?

To mitigate this double tax situation, US is nice (??) enough to provide two potential relief. I say potential because they might not work for everyone. Not nice enough to save the day I guess.


That is Foreign earned income exclusion (individual only) and foreign tax credit (both individual and entities). I will cover this in later posting. Stay tuned!!

Summary of today's posting.

In next posting, I will talk about two basic patterns under US International tax framework.


Disclaimer
Discussions and materials in this posting are for informational and educational purpose only. These are not professional or legal advice.  

1 comment:

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