Posts Tagged ‘effectively connected income’

INTRODUCTION: This article examines the structural conflict between private‑capacityPRI constitutional protections and public‑capacityPUB statutory obligations in the context of federal income taxation, particularly the treatment of Effectively Connected Income (ECI) under 26 U.S.C. § 871(b). The analysis is grounded in the FTSIG PUB/PRI ontology, which distinguishes natural private status from government‑created statutory identities, and argues that…