Income taxation of nonresidents

Electing Resident Alien Status Under Section 7701(b)(4)

[Note:  I am preparing the course materials for an all-day program I am teaching for the California Society of Certified Public Accountants on the taxation of multinational families.  This is a portion of the handout I am writing.] You do not have a green card, and you were not in the U.S. enough days to […]

Form 1040NR Filing, Tax Payment Deadlines

I received an email from a CPA friend of mine today. She and another person in her office disagreed on a seemingly simple question. They were preparing a Form 1040NR for a nonresident alien and wanted to get an extension of time to file the tax return. They both agreed that Form 4868 should be […]

Alimony Payments to Nonresidents

[I am preparing course materials for an upcoming presentation at the 2012 CalCPA Family Law Conference (01 Nov 2012 in Los Angeles, 02 Nov 2012 in San Francisco; the San Francisco event will be webcast) on the international tax aspects of divorce. This is a piece of what I am working on. It is a […]

Property you acquired before coming to the USA

This is a quick little blog post to answer a recurring question for many people out there.  It came up in the course of some work I am doing right now. Situation You are a nonresident of the United States.  Thirty years ago you bought a piece of land in your home country for US$10,000. […]

Nonresidents’ U.S. bank interest earned to be reported to IRS

The IRS came out with their Regulations which tell banks that they must report interest earned by nonresidents.  Up to now, this was not done.  If a nonresident opened a bank account in the United States, the interest earned was not reported to the U.S. government. The bank interest itself is not taxable in the […]

Mexican cross-border families and U.S. taxation

I received an email today from a CPA with an interesting situation.  I shot him a quick email to respond to a question, but the situation is interesting enough that it is worth sharing. His comment: I have a practice in (U.S. city near the US/Mexico border).  I’m seeing a prevalence of a nonresident alien […]

IRS wants US banks to report interest earned by nonresidents

Our government is in the throes of attempting to force U.S. banks to report interest earned by nonresident depositors.  This is stupid on stilts. Bank interest earned by nonresidents is not taxed in the USA.  This is built into the Internal Revenue Code. If nonresidents have a choice where to put their money (and they […]

Russian partner in U.S. partnership pays no U.S. income tax

Here is a recent Private Letter Ruling which parses the combined effect of U.S. tax law and the current income treaty between the United States and Russia. A person in Russia is a partner in a U.S. partnership. It looks like a service partnership (accounting firm, law firm, etc.). The person did his/her work in […]

Bravo House Ways & Means Committee for RSS

I was trolling through the House Ways & Means Committee website looking for hints of the existence of H.R. 4539, a new bill which significantly alters the taxation of nonresident investors in U.S. real estate. To my utter shock, I found that our trusted servants have enabled RSS for Committee activity. Bravo! (If anyone else […]