October 30, 2003 - Phil Hodgen

New California Water’s Edge Law

California has just enacted a change to the water's edge election rules. If the Franchise Tax Board wants a piece of your multinational income (and they always do), you need to know about this. The new law makes it a bit harder to goof things up. It's a good thing. (Registered trademark, all rights reserved, Martha Stewart).
October 3, 2003 - admin

Reporting interest income paid to nonresidents (cont’d)

Currently, nonresidents can earn interest on U.S. bank deposits and the IRS isn't told a thing about it. There's a good reason for it: this helps U.S. banks compete internationally for deposits. The Treasury Department wants to change this. Here is an update to the story and a copy of the Treasury Department's letter to the U.S. Chamber of Commerce about the situation.
Nonresidents with US Activities US Real Estate Investments
October 3, 2003 - admin

Welcome to, v. 2

The old static HTML site is gone -- frames, tables, dozens of little .gifs -- everything. In its place is a Movable Type-powered site. The new site will allow and encourage evolution -- in how the site is organized, how it looks, and the content posted to it. Expect changes. And thanks, Adam, for the work.
Random Speeches, Publications, and Events
August 29, 2003 - admin

Interest paid to nonresidents: U.S. Chamber of Commerce doesn’t like proposed regulations

The IRS has an enquiring mind. Let’s just leave it at that. They like to know everything, because the IRS believes that all of us (the humble taxpayers) lie, cheat and steal.

At the moment, the IRS has a significant knowledge gap for foreigners. A nonresident of the United States can put money in a U.S. bank and earn interest on that deposit. The IRS will never, ever know about that interest, because the bank is not required to report bank interest earned by foreigners to the IRS.

A U.S. taxpayer, by contrast, will receive a Form 1099-INT at the end of the year, reporting the interest earned.... continue reading

Foreign Business Activities in the USA US Real Estate Investments
August 29, 2003 - admin

IRS plans for international tax guidance this year

Every year, the IRS publishes a Priority Guidance Plan. It lists the subject matters in which they plan to publish tax regulations and other administrative guidance during the year.

This year shows an impressively ambitious group of topics in the international tax arena. Here is the list, as published by the IRS:

A. Subpart F/Deferral

# Regulations on the allocation of subpart F income.
# Regulations under section 959 on previously taxed earnings and profits.
# Guidance on the PFIC provisions.

B. Inbound Transactions

# Guidance on cross-border pension distributions.
# Guidance under section 1441.
# Guidance on securities lending.
# Guidance on the treatment of certain financial products for withholding purposes.... continue reading

Foreign Business Activities in the USA US Real Estate Investments