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38 SOI Bull. 1 (2018-2019)

handle is hein.tera/stadeint0038 and id is 1 raw text is: 









The  Statistics of Income (S01) Bulletin is issued quarterly by
the Statistics of Income  Division of  the Internal Revenue
Service. The report provides the earliest published annual fi-
nancial statistics obtained from the various types of tax and
information returns filed, as well as information from periodic
or special analytical studies of particular interest to students
of the U.S. tax system, tax policymakers, and tax administra-
tors. Selected historical and other data tables, previously pub-
lished in the spring issue of the Bulletin are now only available
on SOT's pages  of the IRS Web  site (https://www.irs.gov/uac/
soi-tax-stats-historical-data-tables).
   Information on the availability of supplemental data on the
topics included in this issue or other SOI subjects, may be ob-
tained by  sending an email  to SOT's  Statistical Information
Services at sis(irs.gov, or by writing to the Director, Statistics
of Income Division OS:RAAS:S,  Internal Revenue Service, 1111
Constitution Avenue, NW,   K-Room   4112,  Washington, D.C.
20224.
   The S01  Bulletin is prepared under the direction of Wayne
Kei, Chief,  Data  Dissemination  Section. Paul Bastuscheck
(layout and graphics), Clay Moulton (layout and graphics), Lisa
Smith (layout and graphics editor), and Camille Swick (layout
and graphics) are the editorial staff who prepare the manuscript.
Shannon  Cook,  Emily Gross, Jim Hobbs,  and Beth Kilss also
made  major contributions in the production of this issue. Views
expressed in the article are those of the author and do not nec-
essarily represent the views of the Treasury Department or the
Internal Revenue Service.

NOTE:   When  using information from this report, cite the pub-
lication as follows-

Internal Revenue Service
Statistics of Income Bulletin
Summer   2018
Washington, D.C.


Inside This Issue:

Foreign  Recipients  of U.S. Income, Calendar
Year 2015                                                 2
by Scott Luttrell
U.S.-source income  payments  to foreign persons, as reported
on Form  1042-S, Foreign Person's U.S.-Source Income Subject
to Withholding, rose to $824.3 billion for Calendar Year 2015.
This represents an increase of 13.2 percent from 2014. U.S.-
source income payments  subject to withholding tax rose by 24.2
percent from  2014, which  fueled an increase in withholding
taxes of 13.1 percent. Despite these increases, 85.7 percent of
all U.S. -source income paid to foreign persons remained exempt
from withholding tax. The residual U.S.-source income subject
to tax was withheld at an average rate of 15.6 percent.

Controlled  Foreign  Corporations,  Tax Year 2012        18
by Jason Wenrich
The number  of foreign corporations controlled by U.S. multi-
national corporations increased in 2012 to 88,038. End-of-year
assets ($18.6 trillion), total receipts ($6.9 trillion), and current
earnings and profits (less deficit) before income taxes ($924 bil-
lion) all increased from Tax Year 2010. More than 79 percent
of controlled foreign corporations (CFCs) were concentrated in
the services; goods production; and distribution and transporta-
tion of goods sectors. CFCs were incorporated in 192 different
countries of which over 40 percent were incorporated in Europe.

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