foreign person


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See: stranger
References in periodicals archive ?
FIRPTA imposes a federal withholding tax on gains realized by foreign persons from the sale of US real property.
For any foreign persons with sole ownership of a U.
source payments to foreign persons are commonly exempt from withholding tax.
Second, a foreign person may be able to access controlled technology based on the combination of the technology's type or level of control and the foreign person's home country.
This exemption is justified for foreign corporations owned by foreign persons.
Second, given all of the recent press dealing with the use of derivatives by foreign persons (primarily offshore hedge funds) to convert what would otherwise be U.
Therefore, the mere fact that a foreign person owns USRPI does not trigger any negative tax consequences under IRC section 897.
person or any foreign person subject to the jurisdiction of the U.
In cases where sanctions are not imposed against foreign persons who make transfers covered by the act, the president is required to explain to Congress why sanctions were not imposed.
withholding tax on the full value of the rights conveyed to the foreign person plus any cash payment, to the extent that such income is sourced in the United States.
TRIA provides for a federally funded backstop for insurers in the event of a "certified act of terrorism;" in particular, acts committed by one or more persons acting on behalf of a foreign person or foreign interest.
to have been committed by an individual or individuals acting on behalf of any foreign person or foreign interest, as part of an effort to coerce the civilian population of the U.

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