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Non-Resident Income Taxes Internal Revenue Service

Freeman Law

International Tax Concepts: Tax Residency Status

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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

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

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

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

Holland & Knight LLP

IRS Audit Campaign Targets Nonresident Alien U.S. Real Estate Activities

Holland & Knight LLP on

In 2017, the IRS Large Business & International Division (LB&I) announced a new audit strategy known as "campaigns" that focused on issue-based rather than entity-based examinations, and focusing on those issues that present...more

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

IRS Provides Relief for Nonresident Aliens Affected by COVID-19 Travel Disruptions

Because of travel restrictions, such as canceled flights and stay-at-home orders, the COVID-19 pandemic may have significantly limited a nonresident alien’s ability to leave the United States, regardless of whether the...more

Foodman CPAs & Advisors

Covid-19 and Non-Resident Aliens’ Emergency Time Period in the U.S.

Nonresident alien individuals (NRA) who perform services or other activities while in the United States, and foreign corporations who employ individuals or engage individuals as agents to perform services or other activities...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

Eversheds Sutherland (US) LLP

Substantial Presence? PE? Treasury and the IRS prescribe treatment for tax maladies

The COVID-19 epidemic has resulted in travel restrictions around the globe, and many individuals find themselves stranded outside of the jurisdiction in which they usually work. While individuals may be able to work remotely,...more

BCLP

IRS Expands Medical Condition Exception to Substantial Presence Test to Include Travel Disruption as a Result of COVID-19

BCLP on

In Rev. Proc. 2020-20, the IRS provides relief to nonresident taxpayers who have been in the United States long enough to be considered resident aliens under the substantial presence test of IRC 7701(b)(3) as a result of the...more

Bilzin Sumberg

IRS Releases Guidance on COVID-19 Travel Disruptions

Bilzin Sumberg on

On April 21, 2020, the U.S. Treasury Department and the Internal Revenue Service released three forms of guidance directed at non-U.S. individuals and non-U.S. businesses affected by travel disruptions arising from the...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

Morgan Lewis

IRS Issues Cross-Border Tax Guidance on Travel Disruptions from COVID-19 Emergency

Morgan Lewis on

The Internal Revenue Service (IRS) and the US Department of the Treasury released two Revenue Procedures and a new FAQ on April 21 to provide relief to US residents and alien individuals affected by travel disruptions due to...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

Foodman CPAs & Advisors

Did you know that IRS is running 35 Campaigns?

In January 2017, the IRS Large Business and International Division initially announced the launch of a “compliance campaign process” in which IRS identifies compliance issues that present risk and require a response in the...more

Dickinson Wright

U.S Tax Court Bounces Rev. Rul. 91-32: Sales of Partnership Interests by Foreign Partners May Not be Subject to U.S. Tax

Dickinson Wright on

The practice of tax law is an exercise of statutory interpretation. A recent opinion of the U.S. Tax Court, Grecian Magnesite Mining, Indust. & Ship. Co. v. C.I.R., 149 T.C. No. 3 (July 13, 2017), is illustrative. Grecian...more

Dechert LLP

Newsflash: Tax Court Reverses IRS Revenue Ruling

Dechert LLP on

A recent U.S. Tax Court case, Grecian Magnesite (149 T.C. No. 3, July 13, 2017), has declared invalid the long-standing U.S. government position that a non-U.S. person’s sale of an interest in a partnership (in this case, a...more

Farrell Fritz, P.C.

N.Y.’s 2018 Budget Proposal: Tax Proposals To Watch

Farrell Fritz, P.C. on

Last month, Governor Cuomo presented his budget proposal for NY State’s 2017- 2018 fiscal year. Included in the proposal were a number of tax provisions that should be of interest to closely-held businesses and their owners....more

Baker Donelson

Spotlight On Alabama: A Busy Tax Year in Review

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It has been a busy year for developments in Alabama state taxation. In this tax alert we review many of the significant developments that have occurred over the last 12 months....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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