Foreign Nationals

Topics

May 31, 2025

Tax planning for inpatriates

Individuals relocating to the United States may face an array of income tax and information reporting issues.

May 1, 2023

US estate tax: Not just for US citizens

The application of U.S. estate tax laws to a non–U.S. citizen depends on domicile, situs of assets, and application of a treaty.

June 9, 2022

Certain tax services do not violate US ban on provision of accounting services in relation to Russia sanctions

A document issued Thursday by Treasury offers clarity related to, for example, tax and management consulting services that would not be prohibited by the U.S. sanctions announced last month.

April 5, 2022

IRS eases application process for US residency certification

New procedures will facilitate residency certification where the Internal Revenue Service has not yet processed the applicant’s tax return.

June 1, 2020

Taxpayer’s failure to report foreign accounts was willful

Willful FBAR penalties upheld because taxpayer exhibited willful blindness of or recklessly violated
the FBAR reporting requirements.

May 1, 2020

Foreign pension plans and the US-UK tax treaty

Whether contributions, earnings, and distributions are includible in the taxpayer’s income depends on the type of foreign pension plan and whether a tax treaty exempts an event that is otherwise taxable.

March 12, 2020

Foreign gifts: A common example of undisclosed foreign transactions

Here’s what may happen when a foreign gift has not been disclosed.

January 1, 2020

Relief procedures for certain people planning to renounce US citizenship

The procedures allow qualifying former U.S. citizens who have relinquished U.S. citizenship to comply with their U.S. income tax and reporting obligations without paying any unpaid taxes and penalties.

October 1, 2019

The TCJA: Double taxation for US citizens living abroad

Individuals, who are not afforded the benefit of using indirect foreign tax credits, are unable to reduce their Sec. 965 liability with foreign taxes generated at the foreign company level.

September 6, 2018

Researchers and scholars claim tax treaty benefits

Three recent cases provide tips to decide if it’s worth the time and effort to appeal to the Tax Court.

June 28, 2018

Failure to abandon U.S. residency leads to tax liability

A German citizen’s failure to establish that he was a resident of Germany meant he was a “covered expatriate” liable for tax on stock sale gains.

March 1, 2018

Transnational tax information reporting: A guide for the perplexed

This article alerts the practitioner to when an information return may be necessary.

October 1, 2017

Offshore Voluntary Disclosure Program: Limitation period on credits or refunds

This item explains how the statute of limitations may affect a taxpayer when claiming a refund or credit on an overpayment through amended tax returns while under the OVDP.

October 1, 2017

Reporting foreign trust and estate distributions to U.S. beneficiaries: Part 1

Part 1 (of three) explains the classification criteria of a foreign nongrantor trust or foreign estate for U.S. tax purposes and the proper information reporting after U.S. taxes are withheld.

July 1, 2017

Departing aliens and the sailing permit

It is important to understand compliance requirements should the IRS begin using the sailing permit to aid its collection efforts.

April 1, 2017

New reporting requirements for foreign-owned U.S. disregarded entities

The IRS issued regulations that treat a domestic disregarded entity wholly owned by a foreign person as a domestic corporation separate from its owner for reporting, recordkeeping, and compliance purposes.

April 1, 2017

Tax planning for a nonresident entering the U.S. tax system

This item covers some of the key issues an immigrant faces after entering the U.S. tax system as a nonresident.

March 30, 2017

Form 1040NR enters the 21st century

Nonresident filers can now file their 2016 Form 1040NR electronically.

November 1, 2016

Ethics and Risk Issues in FBAR Preparation

A number of ethics and risk management issues must be considered when preparing and filing FinCEN Form 114.

October 1, 2016

IRS Revises Forms 1042-S and W-8BEN-E for 2016

The IRS issued 2016 versions of Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, and Form W-8BEN-E, Certificate of Status of Beneficial Owner for United States Tax Withholding and Reporting (Entities).