News & Analysis as of

Foreign Taxpayers

Evading 200 Years of Precedent: The IRS's New Foreign Travel Ban Will Revoke or Deny Passports of Taxpayers Owing More than...

Under the new Section 7345 of the Internal Revenue Code coming into effect in January 2018, Congress has given the IRS the power to “certify” the names of delinquent taxpayers to the State Department for purposes of denying...more

Grecian Magnesite Mining v. Commissioner: Foreign Investor Not Subject to US Tax on Sale of Partnership Interest

by McDermott Will & Emery on

In a long-awaited decision, the Tax Court recently held that gain realized by a foreign taxpayer on the sale of a partnership engaged in a US trade or business was a sale of a capital asset not subject to US tax, declining to...more

Are You Affected by the Changes to the Individual Taxpayer Identification Number (ITIN)?

The Internal Revenue Service (IRS) recently announced changes to the Individual Taxpayer Identification Number (ITIN) program that now require some individuals to renew their ITIN. Taxpayers with expiring ITINs will receive a...more

Updated ITIN Procedures

by Charles (Chuck) Rubin on

Foreign individuals who are ineligible to obtain a social security number but who require a U.S. taxpayer identification number can apply for a an Individual Taxpayer Identification Number (ITIN) using Form W-7. The process...more

IRS to Invalidate Unused ITINs Unless Renewed

by Holland & Knight LLP on

The Internal Revenue Service (IRS) is requiring individuals with inactive or old individual taxpayer identification numbers (ITINs) to renew their ITINs. The renewals impact individuals who received ITINs prior to 2013. The...more

The U.S. Treasury Releases New FIRPTA Regulations

by Locke Lord LLP on

On February 17, 2016, the U.S. Treasury released new regulations (the New FIRPTA Regulations) that reflect changes that the Protecting Americans from Tax Hikes Act of 2015 (the PATH Act) made to the Foreign Investment in Real...more

U.S. Pre-Immigration Tax Planning

by Carlton Fields on

The U.S. Pre-Immigration Tax Planning brochure provides information on the U.S. Tax Code, income tax, estate and gift tax, and pre-immigration considerations, in addition to real-world examples. There are no adverse...more

Italy Introduces New Rules to Increase Certainty of Tax Law

by McDermott Will & Emery on

The Italian Government has finally approved the long-awaited act on “certainty of law in the relationships between tax authority and tax payers” (Certainty of Tax Law Act)....more

Foreign Citizen Living In the U.S.? Remember Your FBAR

If you are a foreign citizen that is considered to be a resident for U.S. income tax purposes, you need to be aware that your U.S. tax filing obligation is not limited to the income tax return. U.S. taxpayers (including...more

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

by Pepper Hamilton LLP on

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

by McDermott Will & Emery on

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

by Dentons on

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

by Bilzin Sumberg on

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

by Holland & Knight LLP on

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

16 Results
|
View per page
Page: of 1
Cybersecurity

"My best business intelligence,
in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
Sign up using*

Already signed up? Log in here

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.