Navigating the Once-Obscure German Nonresident Withholding Tax
Founders and executives with equity compensation need to be prepared for state tax exposure, even in states where they do not live. In a landmark decision that reverberates beyond Massachusetts, the Massachusetts Appeals...more
Last Friday, New York’s Governor Hochul delivered the following remarks at the annual meeting of the Business Council of New York State:“Someone asked me today, are we going to raise income taxes? I said, ‘I’m not raising...more
On July 21, 2023, New Jersey Governor Phil Murphy signed Assembly Bill No. S3128/A4694 into law, which implements an aggressive tax treatment of nonresidents who work for New Jersey employers. The law essentially adopts the...more
A taxpayer’s status as a resident or nonresident is not always straightforward. A dual-status taxpayer, for example, may qualify as both a nonresident alien and a resident alien during the same tax year. Typically, this...more
Exempt Payments to Non-Resident Aliens and Federal Withholding - Wages paid to U.S. citizens and residents by a U.S. person are generally subject to federal withholding, subject to certain exceptions. Wages paid to...more
In Matter of Goldman Sachs Petershill Fund Offshore Holdings (Delaware) Corp., the New York City Tax Tribunal held that an upper-tier partnership’s passive corporate partner was subject to the New York City General...more
What does it mean to be a U.S. income taxpayer? Very simply, it means that you are taxable on your worldwide income and gains, even if you don't live full-time in the U.S. Any U.S. citizen is likely already familiar with this...more
Governor Baker announced on Monday, May 17 that Massachusetts will end the COVID-19 state of emergency on June 15, 2021. Given this news, the Massachusetts Pandemic-related Temporary withholding tax rules will expire...more
Employees working remotely outside the UK during Covid-19 may create – and may already have created – expensive tax liabilities for themselves and their employers....more
Overview - In Part I of Saving Florence Nightingale, I mentioned the unprecedented times and opportunities facing traveling nurses during the Corona pandemic. Most of the demand has occurred in places deeply affected by...more
The Internal Revenue Service recently released guidance that may help to prevent some non-resident alien individuals from becoming subject to U.S. tax on their global income because they are physically present in the U.S. for...more
On April 21, 2020, the U.S. Treasury Department and the Internal Revenue Service released three forms of guidance directed at non-U.S. individuals and non-U.S. businesses affected by travel disruptions arising from the...more
The practice of tax law is an exercise of statutory interpretation. A recent opinion of the U.S. Tax Court, Grecian Magnesite Mining, Indust. & Ship. Co. v. C.I.R., 149 T.C. No. 3 (July 13, 2017), is illustrative. Grecian...more
In May 2015, the Abbott Government announced that, as part of its objectives for the Australian federal budget, it will reform the tax residency rules by creating tougher rules and higher income tax bills for the approximate...more