International Treaty Archives - Christopher J. Byrne PLLC

Traditional Individual Retirement Accounts and the Estate Tax Situs Rules for a Non-Domiciliary.

As tax season heats up it is important remember that there are certain things that can still be done to impact the 2020 tax return. An important example of this…

March 8, 2021

Compliance Issues France Germany International Taxation International Treaty Switzerland Tax Compliance

UBS to Share Client Information with France

In recent years, Switzerland’s strict bank secrecy laws have made assets in the country a target of investigation for tax authorities around the world. This week, the Swiss Federal Tax…

October 27, 2016

Foreign Tax Preparation Forms and Filings International Taxation International Treaty

Foreign Earned Income Exclusion or Foreign Tax Credit

It is important to understand the differences between Form 1116 Foreign Tax Credit and Form 2555 Foreign Earned Income as depending on your particular facts and circumstances one could yield…

October 27, 2016

Foreign Tax Preparation Forms and Filings International Taxation International Treaty Tax Compliance

Taxation of Consulate Workers in the United States

Resident aliens working for foreign consulates located within the United States may wonder how much, if any, of their income is subject to U.S. taxation. The first place to look…

October 21, 2016

Foreign Country Filing Considerations Foreign Tax Preparation Forms and Filings Internal Revenue Service International Taxation International Treaty U.S. Withholding

Alimony Payments by a U.S. Citizen to a Nonresident Alien

With an ever expanding global economy and migrating workforce, it comes as no surprise that marriage and divorce transcends borders as well, creating unique tax implications for those involved. Generally,…

October 21, 2016

Foreign Tax Preparation International Taxation International Treaty Tax Compliance

Application of Tax Treaties to U.S. Citizens Residing Abroad

U.S. citizens and residents earning income abroad may find that their income is subject to tax in multiple jurisdictions. Some of the effects of double taxation on foreign source wages,…

August 18, 2016

Compliance Issues FATCA Forms and Filings Internal Revenue Code International Treaty U.S. Withholding

Changes to Form W-8BEN-E

Form W-8BEN-E Certificate of Status of Beneficial Owner for United States Tax Withholding and Reporting (Entities) is a form prepared by a foreign entity which must be provided to a…

July 6, 2016

Internal Revenue Code International Taxation International Treaty Tax Compliance

Stock Redemptions for Nonresident Aliens

The IRS treats a stock redemption as either a dividend or a capital gain. According to Internal Revenue Code § 302, if a stockholder’s equity interest remains relatively the same…

July 5, 2016

Foreign Tax Preparation International Treaty Tax Compliance

Foreign Tax Credit – Federal and North Carolina

When filing a federal tax return, a taxpayer may qualify for the foreign tax credit. The foreign tax credit may be claimed for foreign tax imposed on a taxpayer by…

July 5, 2016

Business Entity Classification Foreign Tax Preparation Internal Revenue Code International Treaty

Foreign Investors in S-Corporations

Pursuant to Internal Revenue Code § 1361, there are certain restrictions to qualify for S-Corporation status; one of which is that a shareholder cannot be a nonresident alien. If a…

June 22, 2016

Foreign Tax Preparation International Taxation International Treaty

Hidden Traps in the Foreign Tax Credit

The Foreign Tax credit is important to keep in mind for any individual who pays or accrues foreign tax on foreign income which is also subject to U.S. tax. Not…

December 31, 2015

Foreign Tax Preparation Forms and Filings Internal Revenue Service International Taxation International Treaty United Kingdom

Alimony payments to nonresidents under the UK- U.S. tax treaty

Generally alimony paid by a U.S. citizen or resident of the U.S. to a non-resident Alien is U.S.-source income, deductible by the payor and reportable by the recipient. Because alimony…

September 11, 2014

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