EFTA01104638Dataset 9
2010-03-1811p4,014w
…emoluments and other fixed or determinable annual or periodical gains, profits and income from sources within the United States; (2) interest paid on deposits by foreign branches of domestic banks (which normally would be foreign source income); and (3) gross proceeds from the sale or other disposition of US stocks and securities. • Note, the gross proceeds concept can result in a US withholding tax under FATCA even though an FFI or NFFE has a loss on the sale or exchange…
https://www.justice.gov/epstein/files/DataSet%209/EFTA01104638.pdf