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Part 45 - "Some" examples where the U.S. creates unrealized "foreign income" before a realization event in the source country
Let There Be Income And There Was Income! The United States has an increasing propensity to create “deemed income” in circumstances where the taxpayer has received no income to pay the tax. In some cases the “deemed income” created is “foreign source” income. In other cases it is purely domestic source. When the “deemed income” is “foreign source” income over which the other country has primary…
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