We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.
Lexology logo
  Request new password

Search results

Order by most recent / most popular / relevance

Results: 1-1 of 1

Tax Court rules on non-resident, professional golfer's treatment of U.S. source royalty and personal service income in Goosen v. Commissioner

  • Fox Rothschild LLP
  • -
  • USA
  • -
  • December 6 2011

Non-residents of the U.S. are subject to U.S. income tax on U.S. source fixed and determinable annual or periodic income, as described in Section 871(a), which income, subject to treaty override, is subject to a flat 30 tax rate without deductions