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Question
What type of income is income received by nonresident alien individuals under life insurance and annuity contracts issued by foreign branch of US life insurance company?
AI accountant’s answer:
Income received by a nonresident alien individual from life insurance and annuity contracts issued by a foreign branch of a U.S. life insurance company is generally considered foreign-source income. The taxation of this income may also depend on the tax treaty between the United States and the individual's country of residence, if one exists. Nonresident aliens are usually subject to U.S. tax on two types of income: effectively connected income (ECI) and fixed, determinable, annual, or periodic (FDAP) income. Foreign-source income from life insurance and annuity contracts issued by foreign branches of U.S. life insurance companies typically do not fall under either ECI or FDAP U.S tax categories. Therefore, these payments are usually not subject to U.S. tax for nonresident aliens. However, I suggest looking into the details of the tax treaty between the United States and the individual's country of residence or consult with a tax professional to understand the specific tax implications on this type of income.
Comment from reviewer
Judah Broussard, EA, JD

The should be considered U.S.-sourced income, not foreign-sourced income, per Rev. Rul. 2004-75.

Not Correct.
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