News & Analysis as of

Tax Liability Non-Resident Income Taxes

DarrowEverett LLP

Massachusetts Court Decision Could Spark State Tax Crackdown Nationwide

DarrowEverett LLP on

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

Rivkin Radler LLP

New York Tax Continues to Inconvenience Nonresidents Working Remotely

Rivkin Radler LLP on

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

Littler

Watch Out New York – New Jersey Wants Its Taxes Too!

Littler on

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

Freeman Law

International Tax Concepts: Dual-Status Taxpayers

Freeman Law on

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

Freeman Law

Exempt Payments to Non-Resident Aliens and Federal Withholding

Freeman Law on

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

Cadwalader, Wickersham & Taft LLP

Nonresident Corporate Partner Subject to NYC Tax on Sale of Partnership Interest

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

Bilzin Sumberg

How Do I Become a U.S. Taxpayer? Let Me Count the Days

Bilzin Sumberg on

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

Bowditch & Dewey

How a Remote Workforce Changes State and Local Tax Requirements

Bowditch & Dewey on

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

Littler

Advice for UK Employers with Staff Working Overseas during COVID-19: Act Now!

Littler on

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

Gerald Nowotny - Law Office of Gerald R....

Tax Planning Considerations for Traveling Nurses During the Corona Virus Pandemic - Part II

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

Goulston & Storrs PC

Relief for Some Non-Resident Aliens Stranded in the U.S. Due to the Coronavirus Outbreak

Goulston & Storrs PC on

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

Bilzin Sumberg

IRS Releases Guidance on COVID-19 Travel Disruptions

Bilzin Sumberg on

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

Dickinson Wright

U.S Tax Court Bounces Rev. Rul. 91-32: Sales of Partnership Interests by Foreign Partners May Not be Subject to U.S. Tax

Dickinson Wright on

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

Littler

Australia: Tax Changes on the Horizon for Expatriates Working in Australia

Littler on

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

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