股利為美國來源與否-IRS回覆與整理 - 投資

前幾個禮拜我也寫信問 IRS 投資美國以外的 ETF 是否算是美國來源收入,
由於怕 IRS 的人誤會, 我有特別強調問題是什麼, 還故意選個名字叫
ex-US 的 VEU 來舉例.

I am a nonresident alien investor from Taiwan. My question is whether
ETFs 100% investing outside US considered as US-sourced income or not.

For example, VEU (FTSE All-World ex-US ETF) is an exchange traded fund
managed by Vanguard Group, Inc.. As its name stated, VEU invests in
stocks of companies around the world except US. According to Vanguard's
website (
https://advisors.vanguard.com/VGApp/iip/site/advisor/investments/taxcenter/prioryeartaxdata/article?file=IWE_TaxFTSEAllWorld2012
) and its tax documents, Vanguard clearly stated "The foreign
income percentage for this fund was 100%."

In short, the ETF is managed by US company but the income is 100%
not from US.

As I know, a NRA from Taiwan is subjected to 30% tax for dividends
paid by US corp in general. According to Pub 519, Chapter 3, the
dividends paid by foreign corporations can be exempt from the 30%
tax. My question is whether VEU meets this condition? i.e. Dividends
from VEU can be exempt from the 30% tax?

===

IRS 的回答其實我不是很確定他的意思.

In most cases, dividend income received from domestic corporations is
U.S. source income. Dividend income from foreign corporations is
usually foreign source income. There is no 30% tax on U.S. source
dividends you receive from a foreign corporation. Please note that
because a mutual fund actually holds the underlying securities in
its name, the mutual fund pays several types of dividends and
distributions that the mutual fund has received on the underlying
securities. You must report all mutual fund dividends and
distributions, including dividends reinvested in the mutual fund,
on your tax return. For more information, please refer to
Publication 519, U. S Tax Guide for Aliens.

===
"There is no 30% tax on U.S. source dividends you receive from a
foreign corporation" 這句看起來有點奇怪. 若不是筆誤, 可以解釋成
雖然 VEU 是 U.S/ source dividends, 但是是 foreign corp 發的, 沒有 30% tax.
(這句 U.S. source 是字面意思而不是照稅務的定義.... 這是我感到不確定的地方)
但要注意報稅時要把 mutual fund 各種不同的 income 詳列清楚.

還是怎麼理解 IRS 的回覆? 請指教

我後來沒空再問 IRS, 若需要的話還請其他人繼續問清楚.

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