Tax Jurisdiction Jurisdictional Issues Bases for asserting jurisdiction Two basic questions in determining to tax international transactions how First, which persons should be taxed? Bases upon which countries assert tax jurisdiction First, a relationship between TP and the personal country E.g., a country may wish to tax any person who is either a or a of the citizen resident country Second, an relationship between TP and economic the country Exists whenever a person derives income from property or activities that are located a w/in country’s borders The set of persons deriving income from sources w/in a country includes n/ only citizens and residents, but also foreign persons Second, what income is subject to tax? Current U.S. system are the basis for taxing the following Personal relationships individuals: U.S. citizens, Resident aliens, and Domestic corporations is the basis for taxing the following individuals: Source of income
Tax Jurisdiction Jurisdictional Issues Bases for asserting jurisdiction Two basic questions in determining how to tax international transactions First, which persons should be taxed? Bases upon which countries assert tax jurisdiction First, a personal relationship between TP and the country E.g., a country may wish to tax any person who is either a citizen or a resident of the country Second, an economic relationship between TP and the country Exists whenever a person derives income from property or activities that are located w/in a country’s borders The set of persons deriving income from sources w/in a country includes n/ only citizens and residents, but also foreign persons Second, what income is subject to tax? Current U.S. system Personal relationships are the basis for taxing the following individuals: U.S. citizens, Resident aliens, and Domestic corporations Source of income is the basis for taxing the following individuals:
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