美国个人所得税制.docVIP

PAGE PAGE 14 U.S. Individual Taxation 1.?Income Tax The United States imposes a net income tax on individuals. See also: Topical Analyses \o United States - Private Investment Income - Topical Analyses section 1.1.Private Investment Income section 1.1. 1.1.?Taxable persons US citizens and residents are subject to taxation on their worldwide income even if they reside outside the United States. Foreign nationals are subject to US income tax if they become US residents or if they derive certain types of income from US sources. Foreign nationals are treated as US residents if they are lawful permanent residents of the United States (i.e. hold a US green card) or if they meet a substantial presence test. The substantial presence test is met if the person is present in the United States for (1) at least 31 days during the current calendar year, and (2) for at least 183 days during the current calendar year and prior 2 years determined by counting each day of presence in the current year as 1 day, each day of presence in the first prior year as one third of a day, and each day of presence in the second prior year as one sixth of a day. Exceptions apply to individuals in exempt categories (i.e. foreign government-related individuals, students, teachers, and trainees) and to individuals who have a closer connection to a home in a foreign country. Married persons may elect to file either a separate income tax return reporting their own income and deductions or they may elect to file a joint tax return reporting the combined income and deductions of themselves and their spouse. Unincorporated entities such as partnerships and limited liability companies (LLCs) may make a voluntary election under the Treasury Department’s “check-the-box” regulations to be taxed as corporations or as pass-through (transparent) entities. 1.2.?Taxable income See also: Topical Analyses \o United States - Private Investment Income - Topical Analyses section 1.2.1.Private Investment Incom