Tax International Trade Immigration

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Check-the-Box Elections: Relevance in the International Context

One of the most powerful tools in cross-border tax planning is the ability to make a “check-the-box” election. Pursuant to the entity classification regulations under Internal Revenue Code §7701 (the “check-the-box...more

The Comity of Nations in a Technological World: Beyond the Border Action Plan

Canada and the United States share the world’s longest international border – more than 5,500 miles coast to coast and more than 7,000 miles when Alaska is included. In 2013, Canada and the United States engaged in more than...more

Report Indicates Wealthy Chinese to Emigrate to US

Many foreigners crave United States citizenship even though it comes with corresponding obligations and responsibilities (i.e., think about tax compliance). CBS News previously wrote about pregnant women from foreign...more

Getting a Green Card Subjects Noncitizens to U.S. Foreign Bank Account Reporting Requirements

A resident or citizen of a country other than the United States who obtains lawful permanent resident status in the United States, often referred to as a “green card,” becomes a resident of the United States for U.S. income...more

Global HR Hot Topic - October 2013: "Floating” Employment Toolkit

When a multinational business or nonprofit decides to launch a presence in some foreign market where it has never done business before by opening a new local office, a new facility or a new factory, its path is clear: The...more

Leaving Mainland America Yet Remaining in the United States—Puerto Rican Residency as an Alternative To Expatriation

OVERVIEW - One of the news items that generates political fireworks each year is the number and names of famous Americans who renounce their U.S. citizenship. According to the Wall Street Journal, the United States is...more

Portugal for Expats: Less Tax and Investor's Visa

Moving into another country prompts all kinds of questions and tax and immigration issues always stand front and center. Portugal is getting to grips with these two in a fresh, easy and innovative way, turning into a very...more

The Price of Leaving: Renouncing U.S. Citizenship Comes with Costly Consequences

The United States is one of the few countries to tax the worldwide-earned income of its citizens and permanent residents. Millions of American citizens residing outside the U.S. have no direct ties to their home country since...more

The 180-Day Rule for Canadian Visitors – Law or Legend?

How Many Days Can I Be in the United States? We get inquiries from time to time from seasonal “snowbirds,” as well as from sales personnel, account managers, and others who make frequent and/or lengthy trips to the United...more

Nonresident Alien Spouse Not Liable for Penalties

There are an unknown number of U.S. citizens married to nonresident aliens. Many of these taxpayers have filed joint income tax returns. Most are likely to have filed joint income tax returns (Form 1040) without having...more

Should Married Nonresident Aliens Elect Joint Return Status?

The recent decisions of the US Supreme Court, (in the Defense of Marriage Act and Proposition 8 cases) to strike down anti-gay marriage legislation may very well produce an increase in immigrant marriages. The actual number...more

I Want to "Leave" in America - Puerto Rican Residency as an Alternative to Expatriation

Overview - One of the things that generates political fireworks each year is the number and names of famous Americans renouncing their U.S. citizenship. The number is 2012 was about 1800. Regardless of whether you are...more

Employees Working Far Away From The Office: A Jurisdictional Nightmare?

Courtesy of technology, employees can work from home or anywhere else. For organizations that have not issued a flat ban on such work, there is a glitch that no one is talking about. What if home (or “summer home”) is in...more

Capital Thinking Updates - June 24, 2013

In This Issue: - General Legislative - Agriculture and Food - Budget and Appropriations - Cybersecurity - Defense - Education - Energy - Environment - Financial Services - Health...more

A Tax Opinion CAn Protect EB-5 VISA Status.

An EB-5 Visa is known as an "investor" visa. The following is an explanation of the EB-5 program...more

EB-5 Visas Applicant Need Tax Opinions

An EB-5 Visa is known as an “investor” visa. The following is an explanation of the EB-5 program...more

Expatriation Lite: Leaving The U.S. Tax System While Retaining Your Citizenship

As many Miami residents who earn income abroad may be aware, the United States is one of only two countries in the world that taxes its citizens and residents (collectively, “U.S. taxpayers”) on their worldwide income. ...more

Nonresident Alien Deposit Interest Reporting Requirements Are Now in Effect

Starting January 1, 2013, all commercial banks, savings institutions, credit unions, securities brokerages and insurance companies must report interest on deposits paid to nonresident alien individuals to the IRS and to the...more

Total Mobility Law: January 2013

Total Mobility Law launched its website this month, as we intensify our efforts towards our professional goal: providing top-notch international legal advice, excellent service, and maximizing profits for our clients. We...more

FATCA - Dual Nationals, Expatriation or Voluntary Disclosure

Many dual nationals, meaning those U.S. taxpayers who retain citizenship in another country as well as having U.S. permanent residence (Green Card) status or U.S. citizenship, may be considering surrendering their U.S. status...more

Staying clear of the IRS - Tips for estate planning and tax law compliance in a global economy

Originally published in Insights Legal Affairs. Do you own a vacation home in Mexico? Have a bank account in Hong Kong? Has your spouse retained Canadian citizenship? Are you a long-term U.S. resident who was born in the...more

Just how is the Expatriation Tax Calculated?

It has been all over the news lately, wealthy U.S. taxpayers, such as, Eduardo Saverin (a Facebook founder), Denise Rich (songwriter), and another eighteen hundred, or so, have forfeited their U.S. citizenship for U.S. tax...more

Non-Citizens Risk Immigration Status for Offshore Bank Accounts

The increased focus by the IRS on foreign income has generated a lot of news and a slew of criminal prosecutions. While US citizens need to consider the possibility of monetary penalties or a long prison sentence, resident...more

IRS: Interest Paid to Nonresident Aliens to Be Reported

Information regarding nonresident alien deposits in the United States could be provided to foreign governments as of January 2013, raising concern among non-U.S. residents holding deposits in the United States....more

Update: Sending Employees to China

August 2012 update on challenges of sending employees to China....more

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