In all cases, the "residence of seller" rule is used in determining the sourcing of income.
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Q6: Losses and deductions, similar to income items,
Q7: Income tax treaties may provide for either
Q8: Dividends received from Leprechaun, Ltd., an Irish
Q9: LocalCo merges into HeirCo, a non-U.S. entity,
Q10: Monika, a nonresident alien, is employed by
Q11: A Qualified Business Unit of a U.S.
Q12: "Inbound" and "offshore" transfers are exempt from
Q13: Julio, a nonresident alien, realizes a gain
Q18: A "U.S. shareholder" for purposes of CFC
Q19: Gain or loss on the exchange of
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