Open AccessSelected US Tax Developments: Avoiding the "Commercial Activity" Traps for Foreign Sovereigns Investing in US Real Estate
Publication year - 2019
Publication title -
canadian tax journal/revue fiscale canadienne
Language(s) - English
Resource type - Journals
ISSN - 0008-5111
DOI - 10.32721/ctj.2019.67.2.ustd
Subject(s) - business , real estate , tax planning , income tax , finance , law and economics , economics , public economics , double taxation , tax avoidance
US tax laws include a favourable exemption for certain types of US income earned by foreign sovereigns and their controlled entities. Unfortunately, however, there are a number of traps relating to the conduct of commercial activities. The applicable rules are not always intuitive, or even rational, so careful planning is needed.
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