A taxpayer had expatriated in November 2010 when he surrendered his legal permanent resident status and therefore was subject to Sec. 877A.
Taxpayers who receive gifts or bequests from individuals who gave up U.S. citizenship or residency will be subject to tax under proposed rules.
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.
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.
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.
This item explains the tax implications for the payers and recipients of alimony from an international perspective.
This article provides an outline of the basic tax-compliance rules, as well as tax planning strategies, for nonresident aliens.
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 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.