Hello from Debra Rudd.
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This week’s topic comes from a question I received a while ago from an anonymous reader:
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Does an immigrant to the US get to apply the basis step up/transition rule if they did not do a MTM election in their first year of US residence?
Hi from Phil, and welcome to the Friday Edition. Every other week you get something about International Tax from me. And every now and then, a Jello Shot from a random airport somewhere. If you want these to stop, just click the unsubscribe link at the bottom of this email.
Your U.S. government (say that in your best reverberating sports stadium announcer’s voice, the way the guy says “Your Los Angeles Dodgers”) is on the move again.
More “transparency for thee, but not for me” stuff from Your Public Servants.
This time, it is aimed at nonresidents who buy U.S.... continue reading
[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 meet the substantial presence test. You want to be a U.S. resident for income tax purposes. Here is how you do it, by making a special election under Section 7701(b)(4) of the Internal Revenue Code.Why
This election is used by nonresident aliens who become residents of the United States after the middle of the year, and do not hold a green card. ... continue reading