Advertisement
Topics

Non-Resident Withholding

Revisiting FIRPTA and return-of-capital distributions

Although the Foreign Investment in Real Property Tax Act applies to foreign holders of U.S. real property interests, U.S. real property holding corporations also may find it advantageous to apply for a withholding certificate.

Recovery of excess FICA taxes paid for foreign employees

Chief Counsel Advice memorandum 202323005 centers on whether an employer is eligible to receive a refund for an overpayment of FICA tax paid on behalf of an employee on a foreign assignment in a year after the calendar year in which wages were paid, without the employer’s first repaying or reimbursing the employee the employee’s portion of Social Security tax.

employee benefits & pensions

Abstract image of pie chart, with pieces being pulled from several directions. IMAGE BY VECTORMINE/ADOBE STOCK

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.

Tax Clinic

Proposed regulations issued on retirement catch-up contributions

IC-DISC commission payment provisions

The role of REITs for foreign investors in US real estate

Signing partnerships’ returns and other tax documents

Practical considerations for taxpayers and advisers following Loper Bright and Corner Post