U.S. Taxation of Foreign Corporations in the Digital Age

Contents I. INTRODUCTION II. U.S. TAXATION OF THE BUSINESS PROFITS OF FOREIGN CORPORATIONS A. Overview B. Taxation of effectively connected income 1. Allowable deductions 2. Defining effectively connected income 3. Force of attraction rule 4. Effectively connected investment income 5. Foreign-source effectively connected income 6. Source of income on sales of tangible property C. Engaged in trade or business 1. In general 2. Purchase and sale of tangible personal property…