News & Analysis as of

Tax Liability Non-Residents

Mintz - Employment Viewpoints

Navigating Massachusetts Taxes after Relocation: Key Takeaways from Welch v. Commissioner of Revenue

Many Massachusetts residents have recently considered taking, or have undertaken, steps to relocate from Massachusetts to jurisdictions with lower or no state income taxes, especially in light of the recently enacted 2023...more

Proskauer - Tax Talks

UK Government Carried Interest Tax Reforms Consultation Process: No New Conditions, Territorial Limits Clarified

Proskauer - Tax Talks on

June 2025 – The UK Government has published its response to the consultation on its proposal to change the tax treatment of carried interest, confirming the expected final shape of the new regime which will take effect from...more

Rivkin Radler LLP

State Taxation of a Nonresident’s Gain from the Sale of Stock –The Shot Heard Round the Country?

Rivkin Radler LLP on

Last month, Bloomberg carried an article about a “small but growing trend” of states that are either cutting their individual income taxes or phasing them out entirely. According to the article, the states adopting these...more

Blank Rome LLP

Massachusetts Court Subjects Nonresident to Income Tax on Gain from Stock Sale

Blank Rome LLP on

In a decision with troubling potential implications, a Massachusetts appellate court held that a nonresident individual was subject to Commonwealth income tax on capital gain from the sale of his stock in the corporation that...more

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

Davis Wright Tremaine LLP

Nonresidents Beware: Oregon's and Washington's Fractional Formula and Apportionment Rules Apply to In-State Property

At $13.99 million for 2025, the federal estate tax exclusion is the largest it has ever been, but it will be reduced by half in 2026, which you can read more about in this advisory....more

Rivkin Radler LLP

Employer to Nonresident Employee: “You Cannot Work in New York”; New York to Employee: “We Will Tax You Anyway”

Rivkin Radler LLP on

You are probably aware that many employers are discarding the fully flexible, remote work policies that were forced upon them – as “nonessential” businesses – during the COVID-19 pandemic[i] and which they retained as an...more

Foodman CPAs & Advisors

Taxpayers Abroad are Underserved and Challenged

The National Taxpayer Advocate 2023 Annual Report to Congress highlights how Taxpayers abroad are underserved and continue to face challenges in meeting their U.S. tax obligations. As a result, the National Taxpayer Advocate...more

Rivkin Radler LLP

You “Placed Your Trust” In New York? You May Be Sorry You Did

Rivkin Radler LLP on

According to a report issued by the National Association of Realtors a couple of days ago, last year saw a large outmigration of people from California and New York, while Florida and Texas experienced a comparably large...more

BCLP

Sovereign investors likely to start paying UK tax - impact on UK real estate investment

BCLP on

The UK government is consulting on bringing overseas sovereign investors in UK real estate within the scope of UK direct tax from April 2024 as part of measures amending the scope of the sovereign immunity tax exemption. ...more

Payne & Fears

[Webinar] Legal & Tax Pitfalls of a Remote Workforce - March 3rd, 9:00 am - 10:00 am PST

Payne & Fears on

Many companies are shifting to remote or hybrid workplaces. Our legal and tax professionals are teaming together to highlight hot-button issues for your remote workforce. TAX PITFALLS •Employment •Income tax •Residency ...more

Bowditch & Dewey

Planning for Retirement: How Attractive is Massachusetts for Estate Tax Planning?

Bowditch & Dewey on

Massachusetts is already an unattractive state of residency from an estate tax planning perspective because of its low estate tax filing threshold of $1,000,000 per person. Once a person’s adjusted taxable estate is over $1M...more

BCLP

Extension of UK trust register limited for non-UK resident trusts with no UK tax liability

BCLP on

Non-UK resident trusts where all the trustees are non-UK resident and where the trust has no UK tax liability or directly-held UK assets will not have to register on the UK trust register simply because they enter into a...more

King & Spalding

Capital Gains Tax (CGT) payable by non-UK resident investors on direct and indirect disposals of UK commercial real estate

King & Spalding on

Non-UK resident investors (Investor) usually acquire UK commercial real estate (UK Property) through non-UK resident companies, for example Jersey limited liability companies. A typical holding structure put in place by an...more

Coblentz Patch Duffy & Bass

Nonresident Service Provider Subject to California Income Tax on Services Provided to California Customers

The California Office of Tax Appeals (“OTA”) recently issued a decision finding that a nonresident sole proprietor, who performed all services outside of California but performed such services for California customers, was...more

Hogan Lovells

German tax treatment of royalties regarding software license and database licenses – Draft guidance of German Federal Ministry of...

Hogan Lovells on

Yesterday the German Federal Ministry of Finance (Bundesfinanzministerium) released a draft circular on the German tax treatment of royalties paid for software and database licenses granted by non-resident licensors....more

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