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Note: The author is not a CPA or tax qualified. This article is for general information purposes, and should not be construed as tax professional guidance. Readers are strongly encouraged to consult their tax professional regarding their personal tax situation.

The Tax Reform Act of 1986 reduced the actual transfer pricing rate to 28%, in the same time raising the bottom rate from 11% to 15% (in fact 15% and 28% became simply two tax brackets).

Moreover, foreign source earnings are for services performed beyond the U.S. If one resides abroad and works well with a company abroad, services performed for that company (work) while traveling on business in the U.S. is taken into account U.S. source income, and not subject to exclusion or foreign breaks. Additionally, passive income from a U.S. source, such as interest, dividends, & capital gains from U.S. securities, or You.S. property rental income, likewise not subjected to exclusion.

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