The National Taxpayer Advocate 2023 Annual Report to Congress highlights how Taxpayers abroad are underserved and continue to face challenges in meeting their U.S. tax obligations. As a result, the National Taxpayer Advocate...more
US Congress will be giving the Internal Revenue Service (IRS) $79.6 billion over the next 10 years in an effort to put the agency back on the path to effective and efficient tax administration. The money will find lots of...more
It is a fact that the phenomenon of human migration has been a major force in the history of the world. Indeed, among the themes that have remained constant during my years of practice, there are two that may be...more
Escape from New York- According to data released by the IRS earlier this year, the pandemic triggered a “wealth migration” that saw high-tax states like New York lose high-income earners to low-tax jurisdictions such as...more
In 2017, the IRS Large Business & International Division (LB&I) announced a new audit strategy known as "campaigns" that focused on issue-based rather than entity-based examinations, and focusing on those issues that present...more
New York Diaspora? Like most every other state in the Union, New York has experienced its share of fiscal stress over the last few decades. The source or cause of its problems? Well, that may depend upon the respondent to...more
On May 30th, the IRS issued Revenue Procedure 2020-20 which provides non-U.S. individuals present in the U.S. some limited relief from the day-count tests for U.S. tax residency and for eligibility for certain treaty...more
On April 21, 2020, the Internal Revenue Service released an FAQ and two revenue procedures addressing concerns that travel disruptions related to the Coronavirus (COVID-19) pandemic could result in unexpected US tax exposure....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
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 23 – 27, 2019. December 20, 2019: The Department of the Treasury’s Financial Crimes...more
The IRS’ new policy regarding employer identification numbers (“EINs”) could significantly delay the formation of new entities, especially by non-U.S. persons, unless practitioners and their clients get very proactive. ...more
On December 13, 2018, U.S. Department of the Treasury and the Internal Revenue Service released proposed regulations (the “Proposed Regulations”) that would amend the current regulations relating to the Foreign Account Tax...more