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Important
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For information call now:
(347) 989-4566
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Additional information
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Internal Revenue Service
Austin Service Center
ITIN Operation
P.O. Box 149342
Austin, TX 78714-9342
IN
1-800-829-1040
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Sales
Through Offices or Fixed Places of Business
Despite any of the earlier rules, if you do not have a tax home in the United
States, but you maintain an office or other fixed place of business in the
United States, treat the income from any sale of personal property (including
inventory property) that is attributable to that office or place of business as
U.S. source income. However, this rule does not apply to sales of inventory
property for use, disposition, or consumption outside the United States if your
office or other fixed place of business outside the United States materially
participated in the sale.
If you have a tax home in the United States but maintain an office or other
fixed place of business outside the United States, income from sales of personal
property, other than inventory, depreciable property, or intangibles, that is
attributable to that foreign office or place of business may be treated as U.S.
source income. The income is treated as U.S. source income if an income tax of
less than 10% of the income from the sale is paid to a foreign country. This
rule also applies to losses if the foreign country would have imposed an income
tax of less than 10% had the sale resulted in a gain.
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