Foreign Nationals

Topics

July 1, 2013

Defining “Attributable to” Under Sec. 897(g)

The lack of regulatory and published guidance has created uncertainty in applying Sec. 897 to determine the amount of gain attributable to a USRPI.

January 1, 2013

Reporting Trust and Estate Distributions to Foreign Beneficiaries (Part II)

This two-part article explains the computations, payment, and reporting requirements for U.S. trust and estate distributions to foreign beneficiaries.

December 1, 2012

Reporting Trust and Estate Distributions to Foreign Beneficiaries (Part I)

This article explains the procedures and tax compliance issues that fiduciaries face before domestic trust or estate distributions are paid or allocated to foreign beneficiaries.

November 29, 2012

New ITIN Procedures Issued for 2013 Filing Season

The IRS promised issued new ITIN procedures for the 2013 filing season.

November 1, 2012

Advising Nonresidents and Recent U.S. Residents on Estate Tax Issues

Understanding the intricacies of residency and domicile is necessary to understand what will be included in a decedent’s estate for U.S. estate tax purposes.

October 4, 2012

IRS Issues Interim ITIN Procedures for 2011 Tax Returns on Extension

The IRS has posted special instructions for certifying acceptance agents to use in certifying identification documents for 2011 tax year filers who are filing on extension—returns that are due by Oct. 15, 2012.

August 9, 2012

TIGTA: IRS Encourages Employees to Ignore ITIN Fraud

TIGTA confirmed allegations from IRS employees that their supervisors were urging them to ignore potential fraud in a program that reviews and verifies applications for ITINs.

July 1, 2012

Homeland Security May Contact U.S. Persons Living Abroad Who Owe Back Taxes

The IRS has established procedures to facilitate tax collection from taxpayers who live outside the United States, including submitting identifying taxpayer information to a database maintained by the Department of Homeland Security.

July 1, 2012

Final Regs. on Reporting Interest on Deposits Paid to Foreign Taxpayers

The IRS issued final regulations outlining the rules requiring U.S. financial institutions to report interest payments to certain nonresident alien individuals of $10 or more per year paid after 2012.

June 22, 2012

IRS Suspends Issuing ITINs Without Original Documentation

The IRS will no longer issue individual taxpayer identification numbers unless the applicants provide original documents, such as passports or birth certificates, or certified copies of those documents from the issuing agencies.

April 1, 2012

Estate Planning for International Clients

It is essential for clients with multiple citizenship or residency to understand that the timing and manner of cross-border wealth transfers fundamentally affect their ability to minimize tax burdens.

February 22, 2012

Supreme Court: Filing a False Tax Return Can Lead to Deportation

The Supreme Court held that a conviction under Sec. 7206 for willfully filing a false tax return (or for aiding and abetting filing a false tax return) is an aggravated felony that can result in deportation.

December 9, 2011

IRS Reminds Dual Citizens and Americans Living Abroad of FBAR, Other Filing Requirements

In a fact sheet, the IRS reminded U.S. citizens and dual citizens of the United States and foreign countries who live abroad about U.S. filing requirements.

September 1, 2011

Tax Court Determines Character, Source of Golfer’s Worldwide Endorsement Income

The Tax Court recently decided Goosen, a case with potentially far-reaching implications for foreign athletes who perform within the United States. The decision has become the leading authority for determining both the character and the source of the endorsement income earned by international athletes.

July 1, 2009