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| Summary: IRS Reproposes "Source" Rules for Compensation Attributable to US and Foreign Services (PDF) Groom Law Group via American Benefits Council  Sept. 3, 2004 Excerpt: In early 2000, the IRS issued a proposed regulation regarding the proper 'sourcing' of compensation (including fringe benefits) for U.S. taxpayers and nonresident aliens. The proposed regulation would replace the 'facts and circumstances' test for individuals that work both within and without the United States during the year with a required allocation of the compensation based on time spent here and abroad. |
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