The meaning of the terms “amend” or “supplement” must be determined in light
of the full text of a social security totalization agreement and the shared expectations of the
contracting governments.
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Foreign Nationals
Foreign Information Returns, Income Tax Returns, and Civil Penalties
To avoid harsh penalties, a taxpayer should timely file all foreign information returns, even if that taxpayer cannot timely file its income
tax return.
The Evolution of U.S. Reporting Requirements for Canadian Retirement Accounts
This item explains the evolution of the IRS reporting requirements for Canadian registered retirement savings plans and registered retirement income funds.
Tax Planning for High-Net-Worth Individuals Immigrating to the United States
Foreign high-net-worth individuals immigrating to the United States should seek advice to minimize exposure to the U.S. income, gift, and estate tax system.
German Who Gave Up U.S. Residency Liable for Exit Tax
A taxpayer had expatriated in November 2010 when he surrendered his legal permanent resident status and therefore was subject
to Sec. 877A.
Rules Are Proposed on Sec. 2801 Tax on Gifts and Bequests From Expatriates
Taxpayers who receive gifts or bequests from individuals who gave up U.S. citizenship or residency will be subject to tax under proposed rules.
IRS Issues Dividend-Equivalent Rules for Notional Principal Contracts and Equity-Linked Investments
The IRS issued regulations under Sec. 871(m) that govern withholding on dividend equivalents received by nonresident individuals and foreign corporations from sources within the United States.
Proposed Rules Govern Taxation of Gifts and Bequests From Covered Expatriates
Taxpayers who receive gifts or bequests from certain individuals who gave up their U.S. citizenship or residency will be subject to tax under rules proposed by the IRS on Wednesday.
Constructive Presence Would Count Under Proposed Residency Rules
The IRS issued proposed regulations that, for purposes of establishing bona fide residency in a U.S. territory, would allow individuals additional days of “constructive presence” in the territories if certain conditions are met.
U.S. Tax Implications of Alimony Payments to U.S. Nonresidents
This item explains the tax implications for the payers and recipients of alimony from an international perspective.
Tax Treatment and Planning Strategies for Nonresident Individuals
This article provides an outline of the basic tax-compliance rules, as well as tax planning strategies, for nonresident aliens.
Final Rules Govern Reporting of Specified Foreign Financial Assets
Individuals who are required to report interests in foreign financial assets to the IRS got guidance on the process in the form of final regulations.
IRS Can Notify a Withholding Agent of Foreign Person’s Incorrect Claim of Withholding Exemption
IRS concluded it has authority to notify a withholding agent that a foreign person’s claim of withholding tax exemption with respect to its income effectively connected with a U.S. trade or business is invalid.
Unused ITINs to Expire Under New IRS Policy
Under a new IRS policy, individual taxpayer identification numbers that are not being used will expire after five years.
Canadians’ Immigration to the U.S.: Taxes Coming and Going If Not Planned Properly
Canadians looking to immigrate to the United States must consider a number of tax issues. Despite similarities in the countries’ taxing systems, some significant differences must be properly planned for to avoid paying significantly higher cumulative taxes. This item focuses on a couple of the major differences that need to be considered before emigrating from Canada.
Withholding Rules for U.S. Citizens and Resident Aliens Working for a U.S. Employer in a Foreign Country
For income tax withholding purposes, the wages of U.S. citizens and resident aliens include all remuneration for services performed as an employee for an employer, regardless of whether the services are performed in the United States.
Nonresident Alien Gamblers Get Similar Treatment as U.S. Gamblers
The D.C. Circuit held that nonresident aliens should measure their gambling gains and losses under the “per-session” approach, the same method that U.S. citizens follow, instead of a "per-bet" approach.
Gambling Gains for Nonresidents Now the Same as for U.S. Residents
A decision by the D.C. Circuit puts nonresident aliens’ gambling gains on a closer footing to those of U.S. residents.
Foreign Citizen Denied Refund of Erroneously Withheld Taxes
The Federal Circuit upheld the IRS’s denial of a request for refund of erroneously withheld taxes because the taxpayer filed his claim for a refund well after the end of the three-year lookback period in Sec. 6511(b)(2)(A).
Cross-Border Pension Rollover Creates U.S. Taxable Income
As the global workforce becomes increasingly mobile, more and more workers must wade through the intricacies of cross-border taxation.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.
