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Non-Resident Income Taxes

Rivkin Radler LLP

New York’s Tax Treatment of Compensatory Restricted Stock and Dividends in the Hands of a Nonresident Executive

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As far back as I can remember, the end of August has always elicited a sense of dread comparable to what many schoolchildren, and a fair number of adults, experience every Sunday afternoon. In retrospect, I cannot say that...more

International Lawyers Network

Establishing a Business Entity in Lithuania (Updated)

1. Types of Business Entities - Investors may choose from the following types of business entities: • Private limited liability company • Public limited liability company • Individual enterprise • Limited...more

Pillsbury - SeeSalt Blog

Try, Try Again—New York’s Convenience of the Employer Rule Sources Nonresident Wages to New York Even During the Pandemic

A New York nonresident taxpayer, Edward Zelinsky, recently filed a notice of exception to a Division of Tax Appeals’ (DTA) determination that he must allocate all his wages to New York under the so-called “convenience of the...more

Littler

Watch Out New York – New Jersey Wants Its Taxes Too!

Littler on

On July 21, 2023, New Jersey Governor Phil Murphy signed Assembly Bill No. S3128/A4694 into law, which implements an aggressive tax treatment of nonresidents who work for New Jersey employers.  The law essentially adopts the...more

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

Do Good Fences Make Good Neighbors? New Jersey Enacts Nonresident Income Tax ‘Convenience of the Employer’ Law

New Jersey enacted Assembly Bill No. 4694 on July 21, 2023, adding a “convenience of the employer” rule in an effort to gain tax revenues from nonresidents assigned to a primary work location in New Jersey who work outside...more

Rivkin Radler LLP

Can You Be Sure You’ve Left New York Before The Sale of Your Business? Will It Matter?

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Hasta La Vista N.Y.- Wealthy individuals continue to leave New York for tax friendlier jurisdictions. Be Prepared- Some of these taxpayers take a very methodical approach toward planning for their departure. They...more

International Lawyers Network

Establishing A Business Entity In Lithuania (Updated)

1. Types of Business Entities - Investors may choose from the following types of business entities: • Private limited liability company • Public limited liability company • Individual enterprise • Limited...more

Rivkin Radler LLP

New York’s Convenience of the Employer Rule – New Jersey and Connecticut Respond

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History is replete with examples of leaders who chose to battle, or who were forced into defending against, enemies on two fronts. Rarely did it end well for the combatant that occupied the middle ground. In a sense, New...more

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

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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

Exempt Payments to Non-Resident Aliens and Federal Withholding

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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

Skadden, Arps, Slate, Meagher & Flom LLP

Navigating the Once-Obscure German Nonresident Withholding Tax

In this episode of Skadden’s “GILTI Conscience” podcast, partners Nate Carden and David Farhat discuss the German nonresident withholding tax with partner Johannes Frey, in the Frankfurt office, and Ryan Lange and Kerim Keser...more

Freeman Law

The Closer-Connection Exception

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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

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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

International Lawyers Network

Establishing A Business Entity In Lithuania (Updated)

1. Types of Business Entities - Investors may choose from the following types of business entities: • Private limited liability company • Public limited liability company • Individual enterprise • Limited...more

McDermott Will & Emery

Weekly IRS Roundup October 25 – October 29, 2021

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 25, 2021 – October 29, 2021... October 25, 2021: The IRS released a memorandum...more

McDermott Will & Emery

Mexican Federal Government Submits Proposed 2022 Economic Plan

McDermott Will & Emery on

Last month, the Mexican federal government sent the proposed 2022 Economic Plan (the Proposal) to the Congress of the Union, which includes the 2022 Federal Budget, as well as the 2022 Revenue Law (Ley de Ingresos) and...more

White & Case LLP

Top considerations –EMEA Tax trends impacting Private Equity Real Estate in 2021

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White & Case has advised a large number of high-profile international clients on cutting-edge, cross-border and domestic private equity real estate deals, providing valuable strategic tax insight to a broad range of investors...more

Cadwalader, Wickersham & Taft LLP

Nonresident Corporate Partner Subject to NYC Tax on Sale of Partnership Interest

In Matter of Goldman Sachs Petershill Fund Offshore Holdings (Delaware) Corp., the New York City Tax Tribunal held that an upper-tier partnership’s passive corporate partner was subject to the New York City General...more

Sullivan & Worcester

The Supreme Court Denies Complaint in New Hampshire v. Massachusetts, Heightening the Importance of Individual Refund Claims

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The United States Supreme Court ("Supreme Court") denied New Hampshire’s bid to strike down as unconstitutional the Massachusetts regulation that governs personal income taxation for nonresidents who have been telecommuting...more

Cole Schotz

“Accidental Americans” Must Pay US Tax On Worldwide Income And Provide Detailed US Tax Reporting

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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

Eversheds Sutherland (US) LLP

SCOTUS denies New Hampshire’s motion challenging Massachusetts’ taxation of nonresident remote workers during Covid-19

On June 24, 2021, the United States Supreme Court held a conference to review New Hampshire’s motion for leave that challenged Massachusetts’ taxation of wages earned by nonresident remote workers during the Covid-19 period....more

Hogan Lovells

Legal implications of remote work arrangements: perspectives from the U.S., UK, and France

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In light of the impact of the global COVID-19 pandemic, employers have made adjustments to facilitate remote working, with some considering maintaining expanded remote work policies even after government restrictions are...more

Blank Rome LLP

Ohio High Court Upholds Taxation of a Nonresident’s Income from Stock Options

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The Supreme Court of Ohio upheld the City of Cleveland’s taxation of a nonresident’s income from stock options even though the income was recognized by the nonresident seven years after the nonresident had ceased working or...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

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