International Tax Question Forum

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International Tax Question

Post by 3|ink » Sun Apr 13, 2014 7:27 pm

What's the difference between FDAP and ECTI? I honestly don't see it. It looks like they completely overlap.
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Re: International Tax Question

Post by 3|ink » Tue Apr 15, 2014 9:50 pm

Fuck
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Jsa725

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Re: International Tax Question

Post by Jsa725 » Tue Apr 15, 2014 10:04 pm

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Last edited by Jsa725 on Fri Oct 24, 2014 11:14 pm, edited 1 time in total.
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Johann

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Re: International Tax Question

Post by Johann » Tue Apr 15, 2014 10:27 pm

The main difference is how connected to the US something is. Pure portfolio income(divs, interest, etc) for just owning stock or loaning money to US corp is FDAP. ECI is essentially being a part of that business like setting up the US corp. It all comes down to presence in the US.
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Jsa725

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Re: International Tax Question

Post by Jsa725 » Tue Apr 15, 2014 10:33 pm

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Last edited by Jsa725 on Fri Oct 24, 2014 11:14 pm, edited 1 time in total.
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Re: International Tax Question

Post by 3|ink » Wed Apr 16, 2014 11:35 am

Thank you both for saving my life.
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Re: International Tax Question

Post by Jsa725 » Wed Apr 16, 2014 12:12 pm

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