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.
Hall income tax and 1960, the court rejected proposals for a general personal income tax. However, in 1981, 1991, and 1999, three different Tennessee Attorneys General issued opinions that a general income tax would not violate the state constitution. In December 2004, a commission established to study the state's tax structure said the Hall income tax was regressive, anti-competitive, and "unfairly selective." However, the Institute on Taxation and Economic Policy (ITEP) said the Hall Tax is actually the only major progressive tax levied in Tennessee—amounting to 0.4 percent of income for high-income taxpayers compared to 0.0–0.1 percent for less affluent Tennesseans. The Tennessee