Income tax in the United States under tax treaties. Foreign persons are taxed on income from a U.S. business and gains on U.S. realty similarly to U.S. persons. Nonresident aliens who are present in the United States for a period of 183 days in a given year are subject to U.S. capital gains tax on certain net capital gains realized during that year from sources within the United States. The states tax non-resident individuals only on income earned within the state (wages, etc.), and tax individuals and corporations on business income apportioned to the state. The United States has income tax treaties with over 65 countries.
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