PUBLICATIONS

TAX PLANNING MATTERS FOR THE FOREIGN NATIONAL

By William K. Norman, Norman & Zak,
​Los Angeles, California

1. U.S. Federal Income Treatment of a Nonresident Alien
A. The following items of gross income of a non resident alien of the United States (“NRA”) are subject to U.S. Federal income tax:
— Items of passive income derived from U.S. sources (not attributable to the conduct of a trade or business within the United States as specially defined such as dividends, interest and royalties are generally subject to 30 percent Federal tax withheld at source unless the rate is reduced…Download full article below

By William K. Norman, Ord & Norman,
​Los Angeles, California

Generally as a matter of legal form only, the IC DISC acts as a sales representative for a related exporter.  Tax benefits for a so-called stand alone DISC acting as an independent sales representative for one or more unrelated suppliers are available as well.  Generally, the related supplier is a parent corporation or commonly owned sister corporation.  The amount of the commissions earned by the IC DISC representing (or buying from) a related supplier are determined under a formula without regard to the actual economic activities of the IC DISC…