Individuals, who are not afforded the benefit of using indirect foreign tax credits, are unable to reduce their Sec. 965 liability with foreign taxes generated at the foreign company level.
Three recent cases provide tips to decide if it’s worth the time and effort to appeal to the Tax Court.
A German citizen’s failure to establish that he was a resident of Germany meant he was a “covered expatriate” liable for tax on stock sale gains.
This article alerts the practitioner to when an information return may be necessary.
Part 1 (of three) explains the classification criteria of a foreign nongrantor trust or foreign estate for U.S. tax purposes and the proper information reporting after U.S. taxes are withheld.
This item explains how the statute of limitations may affect a taxpayer when claiming a refund or credit on an overpayment through amended tax returns while under the OVDP.
It is important to understand compliance requirements should the IRS begin using the sailing permit to aid its collection efforts.
The IRS issued regulations that treat a domestic disregarded entity wholly owned by a foreign person as a domestic corporation separate from its owner for reporting, recordkeeping, and compliance purposes.
This item covers some of the key issues an immigrant faces after entering the U.S. tax system as a nonresident.
Nonresident filers can now file their 2016 Form 1040NR electronically.
A number of ethics and risk management issues must be considered when preparing and filing FinCEN Form 114.
The IRS issued 2016 versions of Form 1042-S, Foreign Person’s U.S. Source Income Subject to Withholding, and Form W-8BEN-E, Certificate of Status of Beneficial Owner for United States Tax Withholding and Reporting (Entities).
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.
To avoid harsh penalties, a taxpayer should timely file all foreign information returns, even if that taxpayer cannot timely file its income tax return.
This item explains the evolution of the IRS reporting requirements for Canadian registered retirement savings plans and registered retirement income funds.
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.
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.