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Income Taxes › Non-Resident Income Taxes

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Pillsbury - SeeSalt Blog

Try, Try Again—New York’s Convenience of the Employer Rule Sources Nonresident Wages to New York Even During the Pandemic

Pillsbury - SeeSalt Blog on

A New York nonresident taxpayer, Edward Zelinsky, recently filed a notice of exception to a Division of Tax Appeals’ (DTA) determination that he must allocate all his wages to New York under the so-called “convenience of the...more

Littler

Watch Out New York – New Jersey Wants Its Taxes Too!

Littler on

On July 21, 2023, New Jersey Governor Phil Murphy signed Assembly Bill No. S3128/A4694 into law, which implements an aggressive tax treatment of nonresidents who work for New Jersey employers.  The law essentially adopts the...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Do Good Fences Make Good Neighbors? New Jersey Enacts Nonresident Income Tax ‘Convenience of the Employer’ Law

Ogletree, Deakins, Nash, Smoak & Stewart,... on

New Jersey enacted Assembly Bill No. 4694 on July 21, 2023, adding a “convenience of the employer” rule in an effort to gain tax revenues from nonresidents assigned to a primary work location in New Jersey who work outside...more

Rivkin Radler LLP

Can You Be Sure You’ve Left New York Before The Sale of Your Business? Will It Matter?

Rivkin Radler LLP on

Hasta La Vista N.Y.- Wealthy individuals continue to leave New York for tax friendlier jurisdictions. Be Prepared- Some of these taxpayers take a very methodical approach toward planning for their departure. They...more

International Lawyers Network

Establishing A Business Entity In Lithuania (Updated)

International Lawyers Network on

1. Types of Business Entities - Investors may choose from the following types of business entities: • Private limited liability company • Public limited liability company • Individual enterprise • Limited...more

Rivkin Radler LLP

New York’s Convenience of the Employer Rule – New Jersey and Connecticut Respond

Rivkin Radler LLP on

History is replete with examples of leaders who chose to battle, or who were forced into defending against, enemies on two fronts. Rarely did it end well for the combatant that occupied the middle ground. In a sense, New...more

Freeman Law

International Tax Concepts: Tax Residency Status

Freeman Law on

U.S. Tax Residency Status - As a general matter, all U.S. citizens and U.S. residents are treated as U.S. tax residents. A non-U.S. citizen is generally classified as a nonresident for U.S. tax purposes unless they satisfy...more

Freeman Law

International Tax Concepts: Dual-Status Taxpayers

Freeman Law on

A taxpayer’s status as a resident or nonresident is not always straightforward. A dual-status taxpayer, for example, may qualify as both a nonresident alien and a resident alien during the same tax year. Typically, this...more

Freeman Law

Exempt Payments to Non-Resident Aliens and Federal Withholding

Freeman Law on

Exempt Payments to Non-Resident Aliens and Federal Withholding - Wages paid to U.S. citizens and residents by a U.S. person are generally subject to federal withholding, subject to certain exceptions. Wages paid to...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

McDermott Will & Emery

Weekly IRS Roundup October 25 – October 29, 2021

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 25, 2021 – October 29, 2021... October 25, 2021: The IRS released a memorandum...more

McDermott Will & Emery

Mexican Federal Government Submits Proposed 2022 Economic Plan

McDermott Will & Emery on

Last month, the Mexican federal government sent the proposed 2022 Economic Plan (the Proposal) to the Congress of the Union, which includes the 2022 Federal Budget, as well as the 2022 Revenue Law (Ley de Ingresos) and...more

Sullivan & Worcester

The Supreme Court Denies Complaint in New Hampshire v. Massachusetts, Heightening the Importance of Individual Refund Claims

Sullivan & Worcester on

The United States Supreme Court ("Supreme Court") denied New Hampshire’s bid to strike down as unconstitutional the Massachusetts regulation that governs personal income taxation for nonresidents who have been telecommuting...more

Cole Schotz

“Accidental Americans” Must Pay US Tax On Worldwide Income And Provide Detailed US Tax Reporting

Cole Schotz on

We have had several matters recently with “Accidental Americans” – that is, non-US persons who became US tax residents by staying in the US for a sufficient number of days. This frequently happens in an understandable...more

Eversheds Sutherland (US) LLP

SCOTUS denies New Hampshire’s motion challenging Massachusetts’ taxation of nonresident remote workers during Covid-19

Eversheds Sutherland (US) LLP on

On June 24, 2021, the United States Supreme Court held a conference to review New Hampshire’s motion for leave that challenged Massachusetts’ taxation of wages earned by nonresident remote workers during the Covid-19 period....more

Hogan Lovells

Legal implications of remote work arrangements: perspectives from the U.S., UK, and France

Hogan Lovells on

In light of the impact of the global COVID-19 pandemic, employers have made adjustments to facilitate remote working, with some considering maintaining expanded remote work policies even after government restrictions are...more

Blank Rome LLP

Ohio High Court Upholds Taxation of a Nonresident’s Income from Stock Options

Blank Rome LLP on

The Supreme Court of Ohio upheld the City of Cleveland’s taxation of a nonresident’s income from stock options even though the income was recognized by the nonresident seven years after the nonresident had ceased working or...more

Bilzin Sumberg

How Do I Become a U.S. Taxpayer? Let Me Count the Days

Bilzin Sumberg on

What does it mean to be a U.S. income taxpayer? Very simply, it means that you are taxable on your worldwide income and gains, even if you don't live full-time in the U.S. Any U.S. citizen is likely already familiar with this...more

Bowditch & Dewey

How a Remote Workforce Changes State and Local Tax Requirements

Bowditch & Dewey on

Governor Baker announced on Monday, May 17 that Massachusetts will end the COVID-19 state of emergency on June 15, 2021. Given this news, the Massachusetts Pandemic-related Temporary withholding tax rules will expire...more

Smith Gambrell Russell

Key Tax Trap for Foreign Individuals Who Move to the United States

Smith Gambrell Russell on

Many individuals who move to the U.S. for work, study or investment, often understand that they will need to be careful to comply with the applicable immigration rules, such as obtaining a visa. And while such persons often...more

Hogan Lovells

Spanish Supreme Court opens the door to refunds of withholding taxes borne by non-EU pension funds

Hogan Lovells on

The Spanish Supreme Court has recently issued a judgment concluding that a Canadian pension qualifies for the same tax treatment as Spanish pension funds and is therefore entitled to obtain the refund of the withholding tax...more

BakerHostetler

New Hampshire v. Massachusetts - Are There Broader State Tax Implications?

BakerHostetler on

Massachusetts is taxing nonresidents who are working outside Massachusetts due to COVID-19. Seems unfair? Well New Hampshire agrees and has asked the US Supreme Court to allow it to bring suit against Massachusetts. Matt...more

Freeman Law

Remote Work Force and State Tax Implications

Freeman Law on

The Covid-19 pandemic has had an impact on our workforce. Companies were forced to quickly respond to a work-from-home model for its employees. Many employees began working from states other than the states in which their...more

Littler

Advice for UK Employers with Staff Working Overseas during COVID-19: Act Now!

Littler on

Employees working remotely outside the UK during Covid-19 may create – and may already have created – expensive tax liabilities for themselves and their employers....more

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