id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
taxlaw-2856	Elkins, David	The Myth of Corporate Tax Residence	2018	39	.pdf	application/pdf	25821	998	48	Under current U.S. tax policy there is an important distinction between U.S.-source income and foreign-source income and between U.S. income tax and foreign income tax. (5) Regarding income attributable to U.S. sources, Pat would pay tax of $254,000, derived from an initial tax liability of $304,000 and an ITC of $50,000.182 From a practical perspective, the United States does not have the jurisdiction to compel all corporations to track and report U.S.-source income, foreign-source income, U.S. income tax incurred, and foreign income tax incurred; nor does it have the jurisdiction to compel all corporations to submit to an audit by U.S. administrators to verify the numbers that it does report.	cache/taxlaw-2856.pdf	txt/taxlaw-2856.txt