Income from Securities |
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There is a special rule determining whether income from securities is effectively connected with the active conduct of a U.S. banking, financing, or similar business.
If the foreign person's U.S. office actively and materially participates in soliciting, negotiating, or performing other activities required to arrange the acquisition of securities, the U.S. source interest or dividend income from the securities (or gain or loss from their sale or exchange) or, for tax years beginning after October 22, 2004, income or gain economically equivalent to such amounts, is attributable to the U.S. office and is effectively connected income.
References/Related Topics
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Page Last Reviewed or Updated: October 16, 2008