Offshore Tax Manual Part 4    - Tax Rules for Non-Resident Aliens and Expatriates How the U.S. is a Tax Haven for Foreign Persons  Exemption for Interest from U.S. Debt or Debt of U.S. Banks or Similar Entities  Exemption for Interest from Portfolio Debt  Exemption for Gains on U.S. Securities  Withholding Rate for Treaty Country Residents  General Tax Rules for Non-Resident Alien Individuals (IRC § 871)  Citizenship, Residence and Domicile  Tax on U.S. Source Earned Income by Individuals  Tax on Trade or Business Income in the U.S.  Tax on Income from U.S. Based Real Property  Tax on Fixed or Determinable Annual or Periodical Income (FDAPI)  Tax on Non-Exempt U.S. Interest & Dividends  Tax on U.S. Source Rents or Royalties  Other Examples of FDAPI  Estate and Gift Tax on U.S. Source Property  Worldwide Taxation of U.S. Citizens & Residents  Prior Rules for Tax Motivated Expatriation  Tax Motivated Expatriation  The Ten-Year Tax on Tax Motivated Expatriates  Income Items Subject to the Ten-Year Income Tax  Assets Subject to the Ten-Year Estate and Gift Tax  Comparison of Tax on NRA and Tax on Expatriates  Uncertainty Regarding Ability of "Taxpatriates" to Return to the U.S.  The Expatriation "Two-Step"  Corporate Expatriation  U.S. Source Withholding

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