Tag Archive for Domestic State Taxation Controversies

Electronic Commerce Taxation and United States Bi-Lateral Treaties

Taxation of electronic commerce from offshore has two main aspects, the United States tax regime from an international perspective and the effect of bi-lateral treaties upon that regime.  A previous writing addressed the first consideration, the general dynamics of the United States tax regime for entry taxation of a non-resident alien or foreign corporation. (1)  The United States is engaged in more than fifty bi-lateral income tax treaties with other sovereigns.  In a general statement, those treaties are designed to mitigate the effects of double taxation.

Income that is generated by a foreign party from activity in the United States can be taxed from the source country, the United States in that case, and the residence foreign country, creating risks of multiple taxation.  Treaties are designed to alleviate that conflict.  The Read More

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United States Taxation of Foreign Electronic Commerce

Introduction

United State taxation of electronic commerce from offshore is to be approached from two perspectives, the United States tax regime from an international perspective and bi-lateral treaties. This writing addresses the first consideration, the tax regime. As stated in a previous segment, international sourced based taxation poses particularly difficult legal risks. (1)

One risk is the electronic commerce and taxation implications. Those issues grapple with electronic commerce and taxation implications when melded with the notion of jurisdiction. Cross-border taxation issues of the authority of a source and resident country Read More

Written by | Posted in International • Tax Controversy