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Internal Revenue Code (IRC) Non-Residents Residency Status

ArentFox Schiff

Residency Determination for US Federal Estate and Gift Tax Purposes and Choice of US Federal Estate Tax Blockers

ArentFox Schiff on

The term “resident” is defined differently for US federal income tax purposes and US federal estate and gift tax purposes. The mismatch in the US resident status under the two tax regimes often gives rise to problems. Thus,...more

Venable LLP

Nonresident Owners Selling a Business with California Contacts? Be Wary of Selling Through a Conduit Holding Entity

Venable LLP on

Clients frequently come to us while in the process of selling interests in California-based businesses. Clients who are not residents of California typically expect that they will not be subject to California income tax on...more

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