Foreign entrepreneurs and others entering the United States, whether for short-term visits or permanently, should be mindful of the complex U.S. income tax and foreign information-reporting rules that may apply to them.
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Foreign Nationals
Key international tax issues for individuals and businesses
U.S. persons abroad and foreign persons living in or with connections to the United States may have responsibilities for filing any of an array of returns and information forms.
Tax planning for inpatriates
Individuals relocating to the United States may face an array of income tax and information reporting issues.
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.
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.
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.
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.
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.
Foreign gifts: A common example of undisclosed foreign transactions
Here’s what may happen when a foreign gift has not been disclosed.
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.
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.
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.
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.
Transnational tax information reporting: A guide for the perplexed
This article alerts the practitioner to when an information return may be necessary.
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.
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.
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.
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.
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.
Form 1040NR enters the 21st century
Nonresident filers can now file their 2016 Form 1040NR electronically.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
