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.
Under a new IRS policy, individual taxpayer identification numbers that are not being used will expire after five years.
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.
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.
A decision by the D.C. Circuit puts nonresident aliens’ gambling gains on a closer footing to those of U.S. residents.
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).
As the global workforce becomes increasingly mobile, more and more workers must wade through the intricacies of cross-border taxation.
The lack of regulatory and published guidance has created uncertainty in applying Sec. 897 to determine the amount of gain attributable to a USRPI.
This two-part article explains the computations, payment, and reporting requirements for U.S. trust and estate distributions to foreign beneficiaries.
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.
The IRS promised issued new ITIN procedures for the 2013 filing season.
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.
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.
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.
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.
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.
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.
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.
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.