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Version vom 22. August 2026, 04:45 Uhr

There is much confusion about what constitutes foreign earned income with respect to the residency location, the location where the work or service is performed, and the source of the salary or fee payment. Foreign residency or extended periods abroad for the tax payer can be a qualification to avoid double taxation.

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Example: Mary, an American citizen, is single and lives in Bermuda. She earns an income of $450,000. Part of Mary's income will be subject to U.S. income tax at the 39.6% tax rate.

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Structured Entity Tax Credit - The government is attacking an inventive scheme involving state conservation tax attributes. The strategy works by having people set up partnerships that invest in state conservation credits. The credits are eventually depleted and a K-1 is issued to the partners who then consider the credits on their personal site again. The IRS is arguing that there is absolutely no legitimate business purpose for the partnership, can make the strategy fraudulent.

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Copyright 2010 by RioneX IP Group LLC. All rights booked. This material may be freely copied and distributed subject to inclusion these copyright notice, author information and all the hyperlinks are kept intact.

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