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Sovereign Wealth Funds Briefing - Categorized | Compliance/Regulation/Legal

Fleischer presents a theory of taxing SWFs

Posted on 05 December 2008

From Typepad.com: Sovereign wealth funds enjoy an exemption from tax under section 892 of the tax code. This anachronistic provision offers an unconditional tax exemption when a foreign sovereign earns income from non-commercial activities in the United States.

The provision, which was first enacted in 1917, reflects an expansive view of the international law doctrine of sovereign immunity that the United States (and other countries) discarded fifty years ago in other contexts….. Full Article: Source


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