http://worldcat.org/entity/work/id/20454600

U.S. taxation of international shipping and air transport activities

" ... discusses the three tax regimes to which nonresident alien individuals and foreign corporations that conduct shipping or air transport activities within the United States may be subject: (1) the general provisions of the Internal Revenue Code of 1986, as amended, for foreign persons with certain modifications; (2) a "reciprocal exemption" provided by [sections] 872(b) and 883; or (3) the similar, but different, exemption available under many U.S. income tax treaties. This portfolio sets forth in detail the U.S. tax rules applicable under each of the three tax regimes, including in particular the requirements that must be satisfied to qualify for an exemption under either [sections] 872(b) and 883 or an applicable U.S. income tax treaty. In this regard, particular emphasis is given to Treasury Regulations issued in 2003 that make it substantially more burdensome for foreign corporations to claim the reciprocal exemption provided by [sections] 872(b) and 883."

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