Income tax in the United States income taxes. This foreign tax credit is limited to that part of current year tax caused by foreign source income. Determining such part involves determining the source of income and allocating and apportioning deductions to that income. States tax resident individuals and corporations on their worldwide income, but few allow a credit for foreign taxes. In addition, Federal income tax may be imposed on non-resident non-citizens, including corporations, on U.S. source income. Federal tax applies to interest, dividends, royalties, and certain other income of nonresident aliens and foreign corporations at a flat rate of 30%. This rate is often reduced
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