id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-346	Brown, Fred B.	An Equity-Based, Multilateral Approach for Sourcing Income Among Nations	2022	77	.pdf	application/pdf	37252	1601	50	For CIN to exist, source countries and residence countries must apply the same source rules in determining the 203. This would be similar to the tax imposed under section 877, under which a nonresident alien who is treated as having expatriated to avoid U.S. tax is subject to U.S. tax on U.S. source income, as expanded under the provision, but with a credit for foreign taxes on income that is taxable solely as a result of section 877.	cache/ftr-346.pdf	txt/ftr-346.txt