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Everything posted by applepenpineapple

  1. Foreign tax credit AND Dividends for US Tax exempt bond funds

      From what I understand, US rules have some significant differences.  Passive income can be either capital gain or ordinary income, and capital gain can be taxed at capital gains rates or ordinary tax rates. The distinction varies by the type of income or property, and duration of holding. Losses from stocks can reduce other capital gains from sale/disposal of property (e.g. bonds, royalties, equipment), but depends on whether the stocks or properties are held shorter or longer than 1 year. Any remaining long term loss reduces short term gain, and short term loss reduces long term gain. Any remaining long term gain is taxed at capital gains rates, and any remaining short term gain is taxed at ordinary rates. The remaining losses after the previous steps can reduce ordinary income (e.g. wages, self-employment, interest, dividends) by up $3,000, then the rest is carried forward. One complexity with US rules on selling bonds is that the profits are divided between ordinary income and capital gains, depending on the the ratio of the holding period to the length of time between the purchase date and the maturity date. Then the capital gains are taxed at either capital gains rates or ordinary tax rates depending on whether the holding period is longer or shorter than 1 year.     This is much different from DE rules, where losses from stocks can only reduce gains from stocks, and passive income (e.g. stocks, bonds, interest, dividends) are taxed at capital gains rates.  And DE rules are much simpler with a flat tax rate.   I only realized now is that DE rules have the losses from sales of bonds grouped together with interest and dividends. I have unrealized losses from bonds which I held onto, which could have completely reduced my taxes on interest and dividends to zero last year if I had sold them instead.     Ok, thinking about it again, I don't need Günstigerprüfung this year, and then it won't have any effect on WA-ESt, because I can reduce all of my Kapitalvermögen to zero, including interest and dividends, by losses from bonds.   The only issue is whether I get the full Grundfreibetrag to reduce my self-employment income, due to part year resident.
  2. Foreign tax credit AND Dividends for US Tax exempt bond funds

      Box for Günstigerprüfung Not Checked 1) Then neither gains nor losses from Kapitalvermögen made after moving away from Germany should not be included in WA-ESt?     I see something about Günstigerprüfung and progressionsvorbehalt in blogs about 7.12.2016 (Az. 11 K 2115/15 E).   Box for Günstigerprüfung Checked 2a) Then gains from Kapitalvermögen made after moving away from Germany should be included in WA-ESt, but not if it was a loss? 2b) But only if it results in a cheaper tax?   3a) If there is a mix of gains from interest/dividends and a net loss from stocks made after moving away from Germany, then only the interest/dividends are entered into WA-ESt, but not the net loss from stocks? 3b) The loss is not reported anywhere on the German tax return?   4) What if there was a net gain from stocks before moving, and net loss from stocks after moving, and the box is checked?     Grundfreibetrag 5) Do part year residents apply the full amount or is it prorated?     Carry forward 6) The loss realized after moving away from Germany cannot be carried forward, so it's better to realize the loss before moving away, for a future chance of returning to Germany (but may not be good for US FTC overall foreign/separate category loss account, unless turning it into a temporary wash sale before moving, and permanently selling after moving)?  
  3. Foreign tax credit AND Dividends for US Tax exempt bond funds

    I'm not a professional, so these are only my opinions, you'll need to consult a licensed accountant.   One thing I'm still not sure about, but theorize that could completely wipe out German taxes in the year of ceasing being a German tax resident, is whether capital losses realized after moving away from Germany but before the end of the year can offset all types of income.   All income, both profits and losses (but not sure if income from retirement account is excluded), after moving away go into Anlage WA-ESt, and gets applied as progressionsvorbehalt to affect the tax on ordinary income. So suppose there are huge unrealized capital losses from stocks from this year. If they are realized before moving away, then the losses can only offset other realized capital gains from stocks. But if the unrealized losses exceed the realized gains, then waiting and selling the excess portion after moving away could then reduce ordinary income as a negative progressionsvorbehalt .   And then if the losses are close to the total amount of all other income, then checking the box for Günstigerprüfung in Anlage KAP would treat all capital income as ordinary income, then the losses in WA-ESt may offset everything.   The other thing I'm not sure about is whether a part year resident would get the full amount of the Grundfreibetrag of 10908€, or if it's prorated by the length of residency during the year, which would affect the negative progressionsvorbehalt calculation.   At least when entering values in such a case into Elster Online gives such a result with the full Grundfreibetrag.     If both ordinary income and capital income are very small,  the box for Günstigerprüfung in Anlage KAP can be checked to see if Elster Online gives a lower tax result.
  4. Foreign tax credit AND Dividends for US Tax exempt bond funds

    I'm not a professional, so these are only my opinions, you'll need to consult a licensed accountant.   If you want to be able to claim more FTC on dividends, you could buy foreign stocks that pay dividends, instead of buying US stocks that pay US dividends. But most countries of the foreign stocks charge 15% withholding on dividends, and some charge 25%, which you then claim as credit against both the German and US taxes.  However, if you buy UK stocks, there is no UK withholding tax.  So then you can put the UK dividends into the passive category for FTC.  Usually the stocks would be ADR shares, and have an ADR fee taken out of the dividend payments.   You could also buy foreign bonds, in foreign companies, for example several cruise companies are registered in Central America.  The interest payments are foreign sourced and go into the passive category.  There is no withholding tax on foreign interest. However, interest is taxed at ordinary rates while qualified dividends are taxed at 0% and 15%.   After you leave Germany and cease paying foreign taxes, but have accumulated a lot of unused foreign taxes for carryover FTC into the future since Germany has much higher tax rates than the US, my theory is that you can still claim FTC on the UK dividends and foreign interest income even if you pay 0% foreign taxes on them, since they are foreign sourced.  You apply the carryover FTC to them, and that would be away to use up your carryover credits (in the passive category) before they expire in 10 years.   Gains and dividends from US ETF stocks (that are in equity stocks) have a 30% discount on German taxes (there are different rules on different types of ETFs).  They go into Anlage KAP-INV instead of KAP. So instead of paying 25% tax, it would be 17.5%. They way it shows up on the tax calculation is that the income amounts on KAP-INV gets reduced to 70% and the multiplied by the 25% tax rate. But losses from regular stocks can't offset gains from ETF for German taxes.  I'm not sure about whether losses from ETF could offset from other types of income.  Entering example cases into Elster-Online might give an answer.  For ETFs, you need to pay  German tax on a theoretical minimum dividend distribution starting from the year after you purchase the ETF, but that minimum dividend percentage (which is very small) is usually exceeded by the real dividend distribution. Only when the ETF doesn't pay at least the minimum distribution, do you have to pay German tax on a fictitious amount of dividend, which you then reclaim back as a cost basis adjustment when you sell the ETF shares. The calculations are made in Anlage KAP-INV.   When you claim foreign tax credits from Germany (like for US taxes on US dividends), when you allocate the German taxes to each amount of income for preparation for entry into part II of 1116, I think it's better to add the credits as a fictitious amount to your real German taxes, prorate that higher amount to each amount of income, and then reduce that amount for the income that had the credits by that amount of credit. This is because the credit affects the 5.5% solidary tax on the 25% capital gains tax and also later if for some reason Germany denies your credit against US taxes, then that would only affects the US sourced income that isn't included in 1116, and avoids a foreign tax redetermination that requires a lot of extra work to amend later.   This is assuming the stocks are with a US broker.  If you have a foreign broker, you may need to report the value of your accounts annually with a specific form, and also with FBAR.       Also, depending on what type and amount of income you have, it may be better or worse to claim FEIE on your earned income compared to claiming FTC (or as itemized deductions). But once you start your election to claim FEIE, you have to do it forever and cannot claim FTC on your earned income, unless you revoke your election, which you have to request permission from the IRS and then I think you're locked into a fixed number of years before you can start claiming FEIE again.   I don't know how to tell when claiming FTC (or as itemized deductions) is better than claiming FEIE. Maybe if you are going to move to another country with a low income tax (lower than the US) after being heavily taxed in Germany, the accumulated unused credits carried over from the German taxes could be applied to the income in the second country. But it depends on whether the income you earn in Germany and the second following country are both in the same income category (for example the foreign branch category for self employment). But if you are employed, then I think that goes into the general category instead.   Or if most of your foreign sourced income is QD+LTCG while your US sourced income is ordinary, since the QD+LTCG adjustment recomputes US taxes as 37% on ordinary income and 15% on QD+LTCG, then claiming FTC on foreign earned income which would be recomputed at 37% tax rate would help to increase the amount of FTC that you can apply.   You would have to calculate it both ways to find out which way is better for you.   I don't know when claiming itemized deduction instead of credits is better.   But typically I think claiming FEIE is better.  Because, the FEIE amount is included in gross income for the allocation of deductions in part I of 1116, but is not part of taxable income. So FEIE reduces the allocation of deductions to your other types of foreign taxable income in part 1 of 1116, and increases the amount of credits you can apply. But if your earned income exceeds the FEIE limitation, then the remainder would go into FTC.   FEIE is also easier than FTC on earned income for paperwork.   The FEIE limitation is against gross earned income before expenses, but after cost of goods sold.   Also, some tax preparation software calculates the FEIE tax worksheet completely wrong and do not factor in the capital gains excess, so you should fill out the worksheets manually by hand to double check.
  5. Foreign tax credit AND Dividends for US Tax exempt bond funds

    Basic information is available on publication 514 and 54, form 1116 instructions, and the US-Germany treaty, which is partially amended by the 2006 protocol. You have to look at which articles of the original treaty has changed, and look at the corresponding part of the protocol for the current rules. If you claim FEIE, then form 2555 instructions.   Codes: Sourcing Codes: foreign tax credits Codes: FEIE   Regulations: you need to find the matching regulations for the code sections   Treaty:   I'm not a professional, so these are only my opinions, you'll need to consult a licensed accountant.   The main things are (in the order of form 1116): sourcing, adjustments to long term capital gains and qualified dividends, US capital loss adjustment, allocation of deductions, allocation and currency conversion of foreign taxes, applying carryover and carryback, adjustment to credit for any foreign or domestic or separate category loss account or recapture, computation of excess foreign tax to be carried over   US sourced dividends (dividends from US companies) do not get re-sourced. They get taxed in both countries, and you claim credits from Germany against the US taxes (up to 25% limit).  You have to calculate the pro rata portion of the US taxes allocated to the US dividends.  I was told by an accountant to divide the dividends by AGI to get the pro rata ratio.  I was wondering if allocating by the QD-LTCG tax worksheet amounts would be acceptable if that results in a higher amount of credits (pro rata by 0%, 15%, and ordinary brackets), but I'm not sure. But claiming credits from Germany is much easier than US FTC, because the German tax return only has 1 single line to fill in to make the claim.   There may be an exception for income from US immovable property (including natural resources) if they are derived from or from the alienation of such property (more likely royalties; maybe but not sure about dividends since it's difficult to tell what the dividends were derived from), which are exempt from German taxes by treaty, and don't go into 1116.  But exempt income still goes into Progressionsvorbehalt to increase your German taxes on ordinary income.  However, gains from sales of stocks in US companies that derive most of their income from US immovable property are still taxed by Germany, but you can claim credit from Germany for US taxes paid on it.   I'm not sure if there exists US dividends that are exempt from US taxes. Are they not tax exempt interest?   If they're US interest that are exempt from US taxes, then I would imagine that you still have to pay tax in Germany. And no FTC credits for the foreign taxes paid on it, since I think the exempt US interest doesn't show up as taxable income on 1040, so wouldn't be included on 1116. And if that income isn't in 1116, then the foreign taxes on it don't go in there either.  But I'm not sure.   US sourced interest (from US banks, bonds, etc), get re-sourced by treaty.  They get taxed in both countries, and you claim FTC from US.   Sourcing of capital gains from stock/funds depends on which country you are resident of. If you are resident in Germany, the gains are foreign sourced. You don't need to re-source. They go directly in passive category.  But if they are exempt from German taxes, like if the shares/funds were purchased before 2009, then capital gains from stocks in US company would be US sourced even if you are resident in Germany, because there is a rule that capital gains from stocks in US companies that aren't taxed by the foreign country of residence of at least 10%,  are then not foreign sourced. But then you may be able to re-source by treaty instead for these gains, but goes into the re-source category instead of the passive category.   Income from a US retirement account may be exempt from German taxes, but I'm not sure. There is a section in the treaty about it.   The adjustment to qualified dividends and long term capital gains is important. Depending on whether your foreign sourced income contains more of either ordinary income or QD+LTCG, the adjustment could be good or bad for the maximum FTC credits.  There is an adjustment exception if your QD+LTCG is under $20,000, but typically it's better to make the adjustment to get more credits (when a large part of your income is from US sourced qualified dividends), unless most of the foreign sourced income is QD+LTCG and your US sourced income is ordinary. This is because the adjustment recomputes the allocation of US taxes to 37% on ordinary income and 15% on QD+LTCG, so less is allocated to QD+LTCG.   Allocation of standard/itemized deductions is more complicated for capital gains, because allocation is to gross income, which includes capital gains before losses, but not capital losses.  So let's say you have $1 million of capital gain, but $999,999 of capital loss, and most of your other income is insignificant in comparison. Then that net of $1 dollar gets allocated almost all of your $12,000 standard deduction. $1 - $12,000 = -$11,999 and now you have a negative amount which causes problems, such as foreign loss account or separate category loss account (or a domestic loss account if that was a US sourced capital gain).  Also complicated is how the QD+LTCG adjustment for US loss adjustment affects the allocation of deductions.   Most software and third party sources calculate the adjustment incorrectly (extremely wrong). They leave out the portion of QD+LTCG that fall into the capital gain excess (the portion covered by standard/itemized deductions) resulting in significantly reduced credits.  Even the IRS instructions/publications leave out instructions about how to deal with capital gain excess and LTCG that have a 0% rate, so you have to factor that in too.   Capital gain excess is included in gross income, but is not in taxable income (because it's the portion offset by deductions), since gross income is income before deductions, while taxable income is gross income after deductions.  So my theory is that capital gain excess does not need a QD+LTCG adjustment since it's not taxable income and does not have a capital gains rate differential, but needs to be included in gross income (line 1a of 1116), but does have to be factored into the US loss adjustment (worksheet B ).   To do the adjustment, it's better to take a modified version of the B worksheet from the 1116 instructions.  B worksheet is simplified because it only includes 2 columns (short term and 15% long term rate).  But typically you'll also have 0% long term rate and also a capital gain excess group for each of short term and long term.  So I modify B worksheet and add 3 additional columns. The line instructions for the 3 new columns will be different for the original 2 columns, depending on whether they are ST or LT, and a gain or a loss.  The reason for the complexity is because of how ST losses can offset LT gains and vice versa, and then in combination with either US or foreign gains or losses. So the worksheet tries to work through each possible combination. Also it tries to work out how US losses have to be allocated pro rata between different separate categories of income (e.g. passive category and resourced category).   Also, if you exceed the AMT tax exemption threshold, you need to an AMT version of 1116 and also it's own AMT carryover credit account. Even if the form instructs you to stop and not to continue with form 6251 when you aren't actually subject to AMT (due to being covered by the AMT version of capital gain excess), you should still complete the form so that you can have a record of AMT carryover into the future in case you ever need it in the next 10 years. Even if the instructions tell you not to attach the AMT forms, it might be a good idea to attach it anyway.   The income that you're allowed to claim German credits against US taxes, I would guess you could also claim against state taxes, but I'm not sure.   Also, be careful that losses incurred from before become German tax resident cannot be carried over for German tax purposes. This also includes wash sale losses disallowed from before that haven't yet been recaptured.  So the income on your US and German tax returns may be completely different.   Also, Germany doesn't have wash sale rules. So your US tax return may show a very high income due to having lots of wash sales, but the German tax return may be very low.  The broker 1099 may have compounded wash sale losses from consecutive buying/selling, and the cost basis doesn't say what portion is from previous wash sale losses.  You either need to manually calculate the real gain for German purposes, or sometimes the broker website has an option to print out your realized gains without wash sale losses factored in.   Also if you're self employed, you may need to file form 8858. You'll also need to consider FBAR. It's probably better to file anyway to be safe, even if you're below $10,000.
  6. I was wondering what is the checkbox on top of the German tax return used for: "Erklärung zur Feststellung des verbleibenden Verlustvortrags"   And does it have any use for net losses from stocks (Aktien)?   I have losses from foreign stocks with foreign brokerage for 2022, which I enter into Anlage KAP lines 19 and 23.  Will I need to checkbox anything on the tax return, or receive a loss certificate from the Finanzamt to qualify to carryover the loss into the future, or is it automatic and requires no user action?
  7. Does anyone know of a US SIM card that I can use in Germany to receive SMS text verification messages from US bank accounts, something that doesn't charge monthly fees and only charges for the minutes and text that you use, like how German prepaid cards work?   I used to simply give the banks my US Skype number, but recently they want to send a verification link or code by SMS, which Skype numbers can't receive if they're sent by SMS short code. So I'm going to ask a friend to buy a SIM from the US and mail it to me.   But I don't see any prepaid SIM cards that don't require you to buy a monthly plan with a monthly fee. The cheapest prepaid SIM card plan that I could find is Ultramobile (T-mobile) PayGo, which is $3 a month, with international roaming allowed.   However, I don't know if SMS short codes work while roaming internationally with the Ultramobile SIM card. I've read that some people were  not able to receive them with some of these prepaid SIM cards.
  8. Grundfreibetrag when moving abroad part year

    I entered some numbers into Elster Online and it gave some solutions to my questions, although I don't know if it's correct.   Elster Online seems to give the full Grundfreibetrag and Pauschale even if I enter part year residence in Anlage WA-ESt. Günstigerprüfung seems to work together with Progressionsvorbehalt from line 6 Anlage WA-ESt. A large negative number in line 6 can wipe out all German tax to zero (even the German tax on investment income), by using Günstigerprüfung to move investment income into ordinary income, so that a negative Progressionsvorbehalt from line 6 can affect all types of income. It seems to work even if the Günstigerprüfung would be more expensive had there been no negative WA-ESt.  Seems like a good case to realize some capital losses after leaving Germany, assuming Elster Online is doing it right (unless it's completely wrong).   Instead of WA-ESt, if I enter a large negative number into Anlage AUS line 36 (Nach DBA steuerfreie Einkünfte / Progressionsvorbehalt), for use with foreign real property (e.g. land use), Elster Online also zeros the taxes.   The Bayern Finanzamt online Progressionsvorbehalt calculator also allows negative amounts to reduce taxes to zero.
  9. Grundfreibetrag when moving abroad part year

    In a scenario when moving out of Germany during part of the year, how is the 10k Grundfreibetrag on self employment income and the 801€ Pauschale on investment income applied or calculated? Is it fully, partially, or none at all?   How would those deductions work together with an election to tax investment income as earned income (Günstigerprüfung), in case the effective tax rate would be less? Is it checkbox line 4 on Anlage KAP? Finanzamt only applies if it's actually cheaper?   I assume the amounts entered into Anlage WA-ESt of income from the period after moving out of Germany would have a progression effect on such an election?   Is the extended unlimited liability after moving abroad out of Germany only for German citizens and some special cases, and not for a typical foreign national self employed person?
  10. Owing self-employment tax to the U.S.

    I just noticed that the mailing addresses is different than their street addresses. Each Rentenversicherung office has a unique post code without a street to receive documents, which is listed on each office's website. The letter which came with the exemption form also lists it on the letterhead.   For example, the Lübeck office street address is: Ziegelstr. 150 23556 Lübeck   But the mailing address is: 23544 Lübeck
  11.   I see in 865(g)(2) the rule about 10% foreign tax paid on the gain, for whether or not the sale of stocks would count as US or foreign sourced.   I can think of 3 cases where the German tax is less than 10%.   1) gains from sales of stock acquired before 2009. As it's 0% rated in Germany, would this then go into re-sourced by treaty category?     2) gains from sales of stock with wash sale loss disallowed. As Germany has no wash sale rule, the wash sale loss disallowed by the US would count towards German calculations, lowering the effective tax rate.   For example: 20,000 proceeds 15,000 cost -------------- 5,000 gross profit -4,000 wash sale disallowed ------------------- 1,000 net profit on German tax return 5,000 net profit on US tax return ----------------------- 26.375% tax in Germany = 263.75 Effective tax rate = 263.75 / 5,000 = 5.275%   As less than 10% was actually paid "with respect to that gain" (which gain? The 1,000 or 5,000?), would it have to be re-sourced by treaty?     3) Then another problem happens to the calculation of the effective tax rate and the allocation of foreign taxes when you either apply this to the aggregate gain from all properties, or to each separate property.          
  12. As a resident in Germany, when claiming foreign tax credits from German taxes on capital gains that came from selling stocks of U.S. companies, do you put them into the re-sourced by treaty or the passive income category on the U.S. tax return?   An accountant previously told me that capital gains from stocks of U.S. companies should go into re-sourced category, along with U.S. interest. But recently I was told instead that any capital gains (which aren't from U.S. immovable property) regardless of where the paying company is established, should go into passive category, when the recipient is a resident of Germany. And that only U.S. interest would go into re-sourced category.   Is this correct, and why would U.S. capital gains and U.S. interest be treated as different categories?   I don't see a difference in their descriptions in the tax treaty. Both articles say these that are derived from a contracting state and paid to a recipient that is resident of the other contracting state may be taxed in the other contracting state (except for alienation of immovable property). No mention of sourcing.   The only thing I can think of is that maybe because withholding tax is taken from foreign interest and dividends, but not from foreign capital gains from sales of stocks.
  13. Owing self-employment tax to the U.S.

    If anyone wants updated mailing addresses for requesting the form, they're probably listed in this PDF.   Oddly, for Deutsche Rentenversicherung Nord, they used to send me the form from Friedrich-Ebert-Damm 245, 22159 Hamburg. But last year's was sent from Zeigelstr. 150, 23556 Lübeck, even though the stamp on the form says Frierich-Ebert-Damm, and the person who signed the form has a 040 telephone number for Hamburg printed on the letter.   So I'm not sure whether to send this year's request to Hamburg or Lübeck. The PDF only lists Lübeck but not Hamburg.    
  14.  @PandaMunich  says to include all income received in the partial year before moving to or after moving away from Germany, on Anlage WA-ESt line 6.    
  15. What's the process and paperwork for reporting zero VAT sales to customers who take the goods out of the EU on a passenger flight in their baggage?   And the customer is: (a) consumer for private use (b) entrepreneur for business use   § 6 (1) 2 UStG seems to relate to both cases § 6 (3a) UStG and § 17 UStDV (im nichtkommerziellen Reiseverkehr) seems to relate only to case (a) with a consumer § 13 (5) UStDV seems to relate to case (b) with an entrepreneur (and maybe § 9 UStDV)     For case (a): I've read that you first invoice the consumer with VAT give them the Ausfuhrbescheinigung form they show the baggage, invoice, and form to the customs office at the airport of exit the customs agent stamps the form the consumer posts the stamped form back to you (must be original?) you refund the customer the VAT   Finally, do you need to send this stamped form to the Finanzamt, and do any special reporting, or do you simply only report the tax free amount in Kennzahl 43 of the USt-VA?     If you already reported the initial payment incl. VAT in Kennzahl 81 (Steuerpflichtige Umsätze zum Steuersatz von 19 Prozent) before receiving the stamped form from the customer, then in the next filing, do you simply input a negative number in Kennzahl 81, and then report the positive number in Kennzahl 43?       For case (b): Should you invoice without VAT? File the Ausfuhranmeldung with ATLAS and give the MRN barcode to the customer, even if value is under 1000€? Would the customs office at the passenger airport be able to process the MRN?       Typically, if I ship it with a courier, I would invoice without VAT, and keep records of the waybill, tracking, and delivery confirmation. If the package value is over 1000€ but below 3000€, then I also file the Ausfuhranmeldung, insert the MRN barcode with the waybill, and then print out the Ausgangsvermerk that's issued when the package exits the EU.    
  16.       Regarding separate loss pots for German taxes, I guess losses from conventional stocks and ETFs (Aktienfonds, Anlage KAP-INV) cannot be mixed with each other.
  17.   Sorry, I did not complete my sentence. What I meant about the withholding tax is that on the papers that come with the 1099 forms issued by US brokerage accounts, there is a page for "foreign income and foreign withholding tax". On this page, I've only seen interest and dividends paid by non-US companies. The interest at 0% tax, and dividends typically at 15% tax. I've never seen capital gains listed on this page.   So I was wondering if this page could be a hint about sourcing rules, if maybe interest paid by a US company should be US-sourced and assigned to the re-sourced by treaty category, since interest from foreign companies show up on that page, and if capital gains from sales of US stocks should be sourced to the recipients country of residence and assigned to the passive category, since capital gains from non-US companies don't show up on that page.  In this case, the US brokerage and ADR administrator assumes the account holder is a US citizen and US resident and withholds the 15% foreign tax on foreign dividends.   But that page appears to be informational, and doesn't seem to be officially part of the 1099 form, so I wouldn't rely on such assumptions. I would prefer to find the part of the US tax code that talk about the sourcing rules.