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International Tax Question

Posted: Sun Apr 13, 2014 7:27 pm
by 3|ink
What's the difference between FDAP and ECTI? I honestly don't see it. It looks like they completely overlap.

Re: International Tax Question

Posted: Tue Apr 15, 2014 9:50 pm
by 3|ink
Fuck

Re: International Tax Question

Posted: Tue Apr 15, 2014 10:04 pm
by Jsa725
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Re: International Tax Question

Posted: Tue Apr 15, 2014 10:27 pm
by Johann
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.

Re: International Tax Question

Posted: Tue Apr 15, 2014 10:33 pm
by Jsa725
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Re: International Tax Question

Posted: Wed Apr 16, 2014 11:35 am
by 3|ink
Thank you both for saving my life.

Re: International Tax Question

Posted: Wed Apr 16, 2014 12:12 pm
by Jsa725
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