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Internal Revenue Code (IRC) Residency Requirements

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

Freeman Law

Tax Court in Brief | Shilgevorkyan v. Comm'r | Deficiency for Disallowed Mortgage Interest Deduction; Qualified Residence Interest

Freeman Law on

Summary: This is a deficiency case involving taxpayer Hrach Shilgevorkyan (Petitioner) and the IRS’s disallowance of a mortgage interest deduction for tax year 2012.  In 2005 Edvard, Petitioner’s brother, purchased the...more

Holland & Knight LLP

When Is a Tax Return "Filed"?

Holland & Knight LLP on

In Notice 2004-45, 2004-2 C.B. 33, the IRS put taxpayers who were asserting to be bona fide residents of the U.S. Virgin Islands (USVI) and who were not following the requirements of meeting the applicable bona fide residency...more

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