One Note Samba
On July 23, 2024, the U.S. Court of Appeals for the D.C. Circuit reversed the U.S. Tax Court in holding that inventory gain recognized by a nonresident alien individual partner on the sale of her interest in a U.S....more
1. Types of Business Entities - The most common types of companies in Estonia are the public limited liability company ("AS") and the private limited liability company ("OÜ"). The OÜ may be compared to a closed...more
The United States Virgin Islands (“USVI”) is an unincorporated territory of the United States.[1] But that doesn’t mean that they’re subject to exactly the same laws as in the United States—especially when it comes to taxes....more
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
Exempt Payments to Non-Resident Aliens and Federal Withholding - Wages paid to U.S. citizens and residents by a U.S. person are generally subject to federal withholding, subject to certain exceptions. Wages paid to...more
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
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
1. Types of business entities - The most common types of companies in Estonia are the public limited liability company ("AS") and the private limited liability company ("OÜ"). The OÜ may be compared to a closed...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 13, 2021 – December 17, 2021. December 13, 2021: The IRS published a memorandum...more
We have had several matters recently with “Accidental Americans” – that is, non-US persons who became US tax residents by staying in the US for a sufficient number of days. This frequently happens in an understandable...more
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
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
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
Using U.S. domestic trusts and private placement insurance products to invest in the U.S. ...more
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
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
Este artículo relacionará los beneficios del uso de fideicomisos estadounidenses para ciertas inversiones entrantes. Fideicomisos de EE. UU., considerados fideicomisos extranjeros con fines fiscales, es una nota....more
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
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
A client recently asked if a foreign national employee was subject to federal withholding taxes. Naturally, since the question involved the U.S. tax code the answer, like the code, is complicated. Fortunately, the IRS has...more
New rules effective from today in the U.K. are likely to have material impact on the tax treatment of payments by a fund to its U.K.-based management executives and service providers. The rules cover many areas of fund...more
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
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