Navigating the Once-Obscure German Nonresident Withholding Tax
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
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
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
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
Governor Baker announced on Monday, May 17 that Massachusetts will end the COVID-19 state of emergency on June 15, 2021. Given this news, the Massachusetts Pandemic-related Temporary withholding tax rules will expire...more
Massachusetts is taxing nonresidents who are working outside Massachusetts due to COVID-19. Seems unfair? Well New Hampshire agrees and has asked the US Supreme Court to allow it to bring suit against Massachusetts. Matt...more
The Covid-19 pandemic has had an impact on our workforce. Companies were forced to quickly respond to a work-from-home model for its employees. Many employees began working from states other than the states in which their...more
Drums. Do you hear them? Along the western shore of the Hudson River. It seems that the unrest which began in New England earlier this year is spreading into the Mid-Atlantic States. The owner of a New York business that...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
Nonresident alien individuals (NRA) who perform services or other activities while in the United States, and foreign corporations who employ individuals or engage individuals as agents to perform services or other activities...more
Overview - In Part I of Saving Florence Nightingale, I mentioned the unprecedented times and opportunities facing traveling nurses during the Corona pandemic. Most of the demand has occurred in places deeply affected by...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
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
On April 21, 2020, the U.S. Treasury Department and the Internal Revenue Service released three forms of guidance directed at non-U.S. individuals and non-U.S. businesses affected by travel disruptions arising from 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
The Internal Revenue Service (IRS) and the US Department of the Treasury released two Revenue Procedures and a new FAQ on April 21 to provide relief to US residents and alien individuals affected by travel disruptions due to...more
The recent pandemic has caused changes to our lives in multiple ways, including shelter-in-place orders and travel restrictions between various countries. ...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