※ 引述《andy2255555 (風鈴)》之銘言：
: 非常感謝大大們的回應
: 一直認為VT不可能退稅 全球市場攪和在一起 變成撒尿牛丸了 怎麼分來源@@
: 如果VT能退稅 有點好奇怎麼分辨各市場來申請退稅
: 但是 但是!!!
: 從以前iceman0603大的文章 (推薦大家可以爬iceman大大的文看看)
: 以及最近再次發的文
: https://www.ptt.cc/bbs/Foreign_Inv/M.1562712239.A.24D.html: 還有從柏格頭論壇搜尋not effectively connected
: 找到這篇文章
: https://www.bogleheads.org/wiki/Nonresident_alien_taxation
: 當中文章有兩段文分別提到
: 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.
: 雖然這不是IRS正式回文
: 但柏格頭觀點看來
: 美國註冊ETF 即使是非美國市場 照樣要扣30%稅啊...
從boglehead文章的reference往上找到這篇文章
Foreign Investors in U.S. Mutual Funds: TheTrouble with Treaties
by Jeffrey M. ColonFordham University School of Law
裡面提到
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.
如此來看，使用NEC退稅將VEA, VWO等配息列為foreign source income也是不
符規定的。 不知道我的理解有沒有錯誤?