目前,我国对美投资业务不断发展,除贸易来往外,已有直接投资、间接投资、发放和购买债券、房地产取得和转让等形式,了解美国税法和司法实践对外国公司和居民的征税立场无疑具有重要的实践意义。不仅如此,美国是实行所得税制度最早的国家之一,1924年首次颁布《国内收入法典》(以下简称“法典”)以来,几经修改和大量的司法解释和判例的补充,已日臻完备,研究其中的涉外部分的规定,对于完善我国的涉外税法,具有重要的理论借鉴意义。 At present, China has continuously developed its investment business with the United States. Apart from trade exchanges, there have been some forms of direct investment, indirect investment, issuance and purchase of bonds, acquisition and transfer of real estate, and understanding of the taxation position of U.S. tax law and judicial practice on foreign companies and residents Undoubtedly has important practical significance. Not only that, the United States is one of the earliest countries to implement the income tax system. Since the enactment of the Domestic Revenue Code (the “Code”) for the first time in 1924, the United States has been gradually revised and extensively supplemented by judicial interpretations and precedents to study The provisions of the foreign-related part, for the improvement of China’s foreign-related tax law, has an important theoretical reference.