Income tax in the United States ordinary income, capital gains, and creditable foreign taxes. The owners then include these items in their own tax calculation. The fund itself is not taxed, and distributions are treated as a return of capital to the owners. Similar rules apply to real estate investment trusts and real estate mortgage investment conduits. The United States imposes tax on all citizens of the United States, including those who are residents of other countries, and U.S. corporations. Federal income tax is imposed on citizens, residents, and U.S. corporations based on their worldwide income. To mitigate double taxation, a credit is allowed for foreign
Legal history of income tax in the United States (1916), the 1913 Act was ruled to be constitutional. A separate excise tax was also imposed on corporations. Subsequent legal actions were concerned with what should be counted as "income" under the 1913 Act. In "Eisner v. Macomber" (1920), the Supreme Court ruled that proportionate stock dividends were not taxable as income, on the grounds that the dividend income was not "severable" from the capital holding from which it was derived. Later decisions, however, have tended to limit this view of "severability," and to uphold the federal statutes as exertions of the power of Congress to tax. The first attempt