Non-Resident Aliens

News & Analysis as of

Nonresident Alien Who Was Previously a U.S. Resident Indicted for Tax Crimes

On March 20, 2014, a federal grand jury in Kansas City, Missouri indicted Victor Lipukhin for tax crimes that occurred from 2002-2007. What makes this indictment stand out when compared against many others is that the...more

Failed Challenge To Interest Reporting Regulations

In 2012, regulations were issued that require banks to report interest paid on deposits of nonresident alien individuals who reside in countries with an exchange of information agreement with the U.S. (even though such bank...more

Court Rules U.S. Banks Must Disclose Nonresident Bank Account Information

As a result of a court decision last week, issued by the District Court in the District of Columbia U.S banks will be required to report interest earned on accounts held be non-resident aliens if the interest earned is $10.00...more

Southeast State & Local Tax: Important Developments - November 2013

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of recent legislation around the U.S....more

Capital Gains Tax on U.K. Property for Non-Residents

According to various reports, the Chancellor of the Exchequer is considering announcing in his Autumn Statement in December that capital gains tax (“CGT”) will be imposed on non-U.K. resident property sellers for the first...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

Indiana Insurance Department Amends Its Non-Resident TPA Application

The Indiana Insurance Department ("Department") recently amended its Non-Resident Third Party Administrator Application ("Non-Resident TPA Application")....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

State & Local Tax Alert: Recent Developments in the State Taxation of Pass-Through Entities

In This Issue: - Nonresident Owner Nexus - Apportionment of Multistate Income - Entity-Level Income Tax Withholding - Composite Returns - Entity-Level Taxes - Issues Unique to S...more

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

Reed Smith Client Wins Residency Case – Despite Being Domiciled in Illinois

This week, the Appellate Court of Illinois, Second District, issued its decision in Grede v. Hamer, holding that an individual was not an Illinois resident, notwithstanding the fact that the individual had not abandoned his...more

Soy Boricua - Rethinking Inbound Tax Planning for Wealthy Latin American Moving to the U.S.

Overview - In case you did not know, Miami is the capital of Latin American. It is the port of entry for Latin Americans from Central and South America. Historically, wealthy Mexicans have liked California and Texas...more

Personal Use Of Corporate Property In A USRPI Holding Company Structure

To insulate the ultimate individual owners from U.S. estate taxes, nonresident aliens often hold U.S. real property in a U.S. corporation, which corporation is owned by a foreign corporation. The foreign corporation is owned...more

NRA Gain On Sale Of Partnership Interest Treated As Creating Effectively Connected Income

Nonresidents are generally not subject to U.S. income taxes on their capital gains if present in the U.S. for less than 183 days in the tax year. Code Section 741 treats the gain from the sale or exchange of a partnership...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

IRS: Substantial Presence Test

The Internal Revenue Service applies a substantial presence test to determine whether a Non-Resident Alien will be considered a US Person due to the amount of days the person was present in the United States. The test is...more

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