Dexter D.J. Samida

U.S. Income Taxation of Foreign Governments: IRS Issues Proposed Regulations on the U.S. Taxation of the U.S. Investment Income of Foreign Governments and Entities Wholly Owned by Foreign Governments
Ronald E. Creamer,Donald L. Korb,Andrew S. Mason,Dexter D.J. Samida,David C. Spitzer,Davis J. Wang,S. Eric Wang, November 9, 2011
Under Section 892 of the Internal Revenue Code, a foreign government is exempt from U.S. federal income taxation on certain investment income. Entities wholly owned by a foreign government - such as sovereign wealth funds and pension plans - that meet certain requirements are generally able to rely...