US 20 | s882 and s864 One More Time

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US Tax

Heide Robson

33 episodes

9 months ago

The podcast for Australian accountants with US clients. Find the experts and information you need to optimise your clients’ cross-border tax position. Help your clients invest or expand from Australia into the US and from the US into Australia.

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All content for US Tax is the property of Heide Robson and is served directly from their servers with no modification, redirects, or rehosting. The podcast is not affiliated with or endorsed by Podjoint in any way.

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US 20 | s882 and s864 One More Time

US Tax

24 minutes 51 seconds

3 years ago

US 20 | s882 and s864 One More Time

Let’s look at s882 and 864 one more time.

The term ‘limited force of attraction’ would make a good movie title, maybe a sequel to ‘The Accountant’. But putting Hollywood aside, The Limited Force of Attraction rule in s864 (c) (3) says that if you have a US Trade or business, then all your US sourced income is ECI.

The speaker in this episode is Alex Oware of O & G Accounting in Lakewood Colorado.

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