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BakerHostetler

[Podcast] Estate and Tax Planning for Globally Mobile Clients: Purchasing U.S. Real Estate by Non-U.S. Persons

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Non-Americans who wish to purchase U.S. real estate should be aware of the tax consequences of owning real estate here. George McCormick discusses these tax issues and steps to minimize their impact....more

BakerHostetler

[Podcast] Estate and Tax Planning for Globally Mobile Clients: Estate and trust planning by non-Americans for American family...

BakerHostetler on

Non-Americans who undertake estate and trust planning for their American citizen or resident family members should be aware of the unique tax issues that face Americans and consider these issues when doing their planning....more

BakerHostetler

[Podcast] Estate and Tax Planning for Globally Mobile Clients: Pre-immigration Planning for Moving to the United States

BakerHostetler on

Individuals considering moving to the United States should be aware of the tax consequences of becoming a U.S. resident and take advantage of tax planning opportunities before moving here. George McCormick discusses these...more

Cozen O'Connor

Treasury Issues Game-Changing Final Regulations on Domestically Controlled REIT Status

Cozen O'Connor on

The United States Department of Treasury issued final regulations (Final Regulations) that arguably change the test (DC Test) for determining whether a REIT is a domestically controlled qualified investment entity (DC-REIT)....more

Allen Barron, Inc.

What Happens If You Don't File an FBAR

Allen Barron, Inc. on

It is common for a US taxpayer to ask “what happens if you don’t file an FBAR or a Form 8938, Statement of Specified Foreign Assets with the IRS? Why do I have to worry about filing an FBAR in San Diego or anywhere in the US,...more

Foodman CPAs & Advisors

Todas Las Fuentes De Ingresos Deben Reportarse En La Declaración De Impuestos

El 3/6/24, el IRS publicó un recordatorio a todos los contribuyentes de que todas las fuentes de ingresos deben declararse en su declaración de impuestos. El IRS está prestando mucha atención a todas las fuentes de ingresos...more

Foodman CPAs & Advisors

All Sources Of Income Must Be Reported On Tax Return

On 3/6/24, the IRS released a reminder to all taxpayers that all sources of income must be reported on their tax return. The IRS is paying close attention to all sources of income derived from digital asset transactions, the...more

Buchalter

FBARs, FATCA, and Foreign Nationals: Where are We Headed?

Buchalter on

There has been a legal shakeup this summer in the world of “FBARs”—Reports of Foreign Bank and Financial Accounts. New developments have been popping up nearly every week, whether from a court decision, as a result of a...more

Rivkin Radler LLP

Foreign Individuals Holding U.S. Real Property, or Left Holding the Bag?

Rivkin Radler LLP on

There have been some interesting developments of late with respect to the ownership of real property in parts of the English-speaking world. For example, Canada has imposed a temporary ban on the purchase of such property by...more

McDermott Will & Emery

New IRS Funding Will Be Used to Focus on Tax Compliance of Non-US Citizens and Residents

McDermott Will & Emery on

US Congress will be giving the Internal Revenue Service (IRS) $79.6 billion over the next 10 years in an effort to put the agency back on the path to effective and efficient tax administration. The money will find lots of...more

Holland & Knight LLP

IRS anuncia amnistía fiscal internacional nueva hasta el 30 de septiembre de 2022

Holland & Knight LLP on

El servicio de impuestos internos de Estados Unidos (Internal Revenue Service o IRS) recientemente anunció una amnistía nueva que permite presentar ciertas declaraciones de 2019 y 2020 sin multa antes del 30 de septiembre de...more

Rivkin Radler LLP

Moving to the U.S.? Have You Planned for the Estate and Gift Taxes?

Rivkin Radler LLP on

It is a fact that the phenomenon of human migration has been a major force in the history of the world. Indeed, among the themes that have remained constant during my years of practice, there are two that may be...more

Pietragallo Gordon Alfano Bosick & Raspanti,...

Do Whistleblowers Have To Be American Citizens?

The United States government has four primary whistleblower statutes and reward programs: •The Federal False Claims Act (“FCA”)- •The Securities and Exchange Commission (“SEC”) Whistleblower Program- •The Internal...more

Freeman Law

The Closer-Connection Exception

Freeman Law on

While the “substantial presence” test often determines whether a nonimmigrant alien individual will be treated as a U.S. person for federal tax purposes, the test is subject to an important exception: the closer-connection...more

Freeman Law

The Substantial Presence Test

Freeman Law on

The “substantial presence” test often determines whether a nonimmigrant alien individual will be treated as a U.S. resident for federal tax purposes.  The test is objective and mechanical.  It provides that an alien...more

Bradley Arant Boult Cummings LLP

EB-5 Enforcement on the Uptick

The EB-5 Immigrant Investor Program is one that attracts its fair share of attention, not all of it good, and too much of it from organizations named with that part of the alphabet — SEC and DOJ — that can strike fear in the...more

Goulston & Storrs PC

Relief for Some Non-Resident Aliens Stranded in the U.S. Due to the Coronavirus Outbreak

Goulston & Storrs PC on

The Internal Revenue Service recently released guidance that may help to prevent some non-resident alien individuals from becoming subject to U.S. tax on their global income because they are physically present in the U.S. for...more

Akerman LLP

Update: IRS Provides Relief for U.S. and Non-U.S. National Non-Residents with Substantial Presence Due to the Coronavirus

Akerman LLP on

With the restrictions on travel both into and out of the U.S. as a result of the rapid spread of the coronavirus (COVID-19) pandemic, non-U.S. or non-resident individuals (NRA) have been forced to spend a significantly...more

Carlton Fields

Immigration and Tax Issues for Nonresident Aliens Subject to Unexpected Travel Restrictions

Carlton Fields on

The recent pandemic has caused changes to our lives in multiple ways, including shelter-in-place orders and travel restrictions between various countries. ...more

Holland & Knight LLP

U.S. Income Tax Residence and the Coronavirus

Holland & Knight LLP on

With the unfortunate emergence and rapid spread of the coronavirus (COVID-19) pandemic, there are many non-U.S. individuals who will be spending significantly longer than expected in the United States this year....more

Bracewell LLP

Straight from the Source: Proposed Regulations Seek to Implement TCJA Changes to Source of Income Rules, Altering Treatment for...

Bracewell LLP on

The source of income is a critical component of U.S. tax rules for both U.S. taxpayers operating internationally (namely, with respect to foreign tax credit planning) and foreign persons with investment or other activity in...more

Proskauer Rose LLP

ERISA Newsletter - Third Quarter 2019

Proskauer Rose LLP on

In this edition of our Newsletter, we take a look at a pair of cases that, while unrelated, together remind us of the importance of having clear plan rules in place that reflect the plan sponsor’s intention. The first article...more

Wilson Sonsini Goodrich & Rosati

Recent Guidance Regarding Withholding on Certain Transfers of Partnership Interests by Non-U.S. Persons

On April 2, 2018, the U.S. Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-29, "Guidance Regarding the Implementation of New Section 1446(f) for Partnership Interests That Are Not Publicly...more

Epstein Becker & Green

March 2017 Special Immigration Alert

President Trump Issues Revised Executive Order on Travel - Today, President Trump issued a revised executive order on travel that becomes effective at 12:01 a.m. EDT on March 16, 2017 (“March 16 EO”). The March 16 EO...more

Gerald Nowotny - Law Office of Gerald R....

Tax-Savvy Planning for Foreign Business Owners Seeking Temporary U.S. Residence: Alternatives to the EB-5 Visa

The EB-5 Visa program has been widely promoted as a legal basis for foreign business owners to gain conditional residency followed by permanent residency in the United States. The program is a great solution to the...more

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