Foreign Taxpayers

Did Sergio Garcia Lose in Match Play with the IRS?

One of the most recognizable names in professional golf—although not the most winning name, having never won a major golf tournament—is Sergio Garcia. He is especially known for his tree shots, the latest of which was a...more

Foreign Taxpayers Can Benefit Despite Proposed Regulations

Proposed regulations on swap payments sound like bad news for foreign taxpayers who have used them to avoid paying U.S. withholding taxes. But there are ways to structure a swap and still take advantage of the favorable tax...more

New ITIN Procedures Complicate U.S. Tax Compliance

On June 22, 2012, the IRS announced interim changes, including more stringent requirements, to its procedures for issuing new individual taxpayer identification numbers (ITINs). ITINs are nine-digit numbers issued for tax...more

Tax Considerations for Employment Lawyers

Okay, let’s admit it—plenty of us had absolutely no interest whatsoever in becoming tax specialists when we started law school. And so here we are, all these years later, serving as employment counsel to our corporate...more