Definition:
Foreign source income is generally not treated as ECI, but there are a few exceptions for certain items of income that are attributable to a U.S. office or fixed place of business. IRC §864(c)(4) and §864(c)(5). See Pages 4 and 15
Foreign source income is generally not treated as ECI, but there are a few exceptions for certain items of income that are attributable to a U.S. office or fixed place of business. IRC §864(c)(4) and §864(c)(5). See Pages 4 and 15