id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
ftr-365	Keinan, Yoram	The Case for Residency-Based Taxation of Financial Transactions in Developing Countries	2022	67	.pdf	application/pdf	28787	1541	57	The Case for Residency-Based Taxation 53 D. Investing and Trading in Securities As set forth above, if a foreign person conducts business activities in the United States, it will generally be subject to U.S. income tax on its income that is effectively connected with that trade or business. On the other hand, source countries today rarely exercise any right to tax interest income earned by foreign portfolio lenders and, where bilateral treaties are in force, tend to tax portfolio dividend income at a zero to 15% withholding rate.	cache/ftr-365.pdf	txt/ftr-365.txt