※ 引述《andy2255555 (风铃)》之铭言：
: 非常感谢大大们的回应
: 一直认为VT不可能退税 全球市场搅和在一起 变成撒尿牛丸了 怎么分来源@@
: 如果VT能退税 有点好奇怎么分辨各市场来申请退税
: 但是 但是!!!
: 从以前iceman0603大的文章 (推荐大家可以爬iceman大大的文看看)
: 以及最近再次发的文
: https://www.ptt.cc/bbs/Foreign_Inv/M.1562712239.A.24D.html: 还有从柏格头论坛搜寻not effectively connected
: 找到这篇文章
: https://www.bogleheads.org/wiki/Nonresident_alien_taxation
: 当中文章有两段文分别提到
: US withholding tax applies regardless of the actual assets held by a US
: domiciled ETF.[6] Even if all of the ETF's assets are non-US stocks, the US
: will still take 30% or lower treaty rate in dividend tax.
: This means that a US domiciled ETF containing non-US bonds or non-US stocks
: suffers the standard 30% or lower treaty rate US tax on dividends.
: 虽然这不是IRS正式回文
: 但柏格头观点看来
: 美国注册ETF 即使是非美国市场 照样要扣30%税啊...
从boglehead文章的reference往上找到这篇文章
Foreign Investors in U.S. Mutual Funds: TheTrouble with Treaties
by Jeffrey M. ColonFordham University School of Law
里面提到
In contrast to the favorable U.S.tax regime for foreign direct investment,
Subchapter M historically has been less hospitable to foreign investment.
Before 2004, Subchapter M recharacterized only a fund’s net capital ga
ins and tax-exempt interest when they were distributed. A fund distribution was
therwise treated as a U.S. source dividend even though it was economicall
y attributable to the fund's underlying foreign source interest,
dividends, or short-term capital gains. Consequently, a foreign investor in
a U.S. mutual fund often
faced a significantly higher U.S.tax burden than if the investor had earned
directly his or her share of the fund’s income.
To encourage foreign investment in U.S. mutual funds, Congress amended in 2004 s
ections 871(k) and 881(e)of the
Internal Revenue Code (Code)to exempt from tax mutual fund dividends paid to
foreign investors if the dividends are attributable to a fund's interest
income and short-term capital gains. The stated goal of the legislation was
to tax foreign mutual funds investors on the same basis as if they had directly
earned their share of the fund's underlying income.
The legislation, however, fails to fully implement this policy goal. In partic
ular,only U.S. source interest is reclassified; foreign source interest and
dividends are not reclassified, and when they are distributed to a foreign
shareholder, they are a taxable U.S.source dividend. Consequently, a
foreign investor that owns a global money market, bond, or stock fund will
be taxed on the fund’s foreign source income even though it would have been
exempt from U.S. tax had the foreign
investor directly earned the foreign source income.
如此来看，使用NEC退税将VEA, VWO等配息列为foreign source income也是不
符规定的。 不知道我的理解有没有错误?