Foreign Taxpayers

News & Analysis as of

U.S. Taxpayers Living Overseas: The June 15th Automatic 2-Month Extended Deadline and Other Filings Extensions

While most U.S. taxpayers must file their taxes by April 15th, U.S. taxpayers living abroad have additional options to extend the deadline of their filing due date. These extensions provide convenience as well as important...more

International Tax Grows Up: The Tax Section at 75, Subpart F at 53, and the Foreign Tax Credit at 97

As the Tax Section celebrates its 75th anniversary, I was asked to reflect on the Section’s contribution in the international tax arena and on how the Section’s international community has grown. I started by recognizing the...more

Court Weighs in on Deadline for Filing FTC Refund Claims

On September 19, 2014, the U.S. Court of Federal Claims issued its opinion in Albemarle Corp. v. United States, No. 12-184T, holding that it lacked jurisdiction over the taxpayer’s claim for refunds based on foreign tax...more

Taxable In Canada? Not A Black And White Situation

In Black v. The Queen (2014 TCC 12), Lord Conrad Black argued that he was not subject to tax in Canada on certain income and taxable benefits. Both Lord Black and the CRA agreed that he was a resident of both Canada and the...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

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