Paula Singer

Paula N. Singer, Esq. a practice leader with Thomson Reuters ONESOURCE Nonresident Alien Taxation and award-winning author has over 30 years of experience as a tax lawyer specializing in cross-border tax issues for individuals, businesses, trusts, and estates. In 1994, Paula co-founded Windstar Technologies, Inc., to provide an easy-to-use and understand software solution for international tax compliance and reporting. A nationally recognized international tax attorney and partner in the law firm Vacovec, Mayotte and Singer LLP, in Newton, Massachusetts, Paula’s practice has concentrated in international tax matters for individuals, businesses, trusts, and estates. She has provided individuals and organizations with tax planning as well as compliance services for individuals relocating internationally since 1978. Paula is a frequent speaker and author of over 80 published articles and is the author of numerous tax guide books. Her articles on international tax topics have appeared in AILA publications, Tax Analysts’ Tax Notes International and Tax Notes as well as their online services, West and RIA publications, and bar association publications. Paula assisted the IRS and NAFSA with the development of Form 1040NR-EZ. Her comments on proposed regulations under section 7701(b) on the substantial presence test and under section 1441 on withholding on payments to foreign persons were incorporated into the final regulations under each section. Paula was a panelist with IRS International Issues Specialist, Lowell Hancock on two IRS webcasts on TaxTalkToday.tv “US Tax Withholding Issues in the Global Business Economy” Dec 2002 and on “Understanding U.S. Income Tax Treaties”, Mar 2008 and on a series of audio seminars in 2009 sponsored by the immigration portal ILW.com. The IRS has used Paula’s tax guidebooks to train their personnel. Paula is also co-author with Prof. Cynthia Blum of Rutgers Law School of two law review articles, “A Comprehensive Policy for U.S. Residence-Based Taxation of Individuals” published in 2008 by the Vanderbilt Journal of Transnational Taxation and “A Proposal for Taking the Complexities out of U.S. Retirement Distributions to Foreign Nationals’ published in 2012 by the Florida Tax Review, the law review of the University of Florida’s graduate tax program.

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Why Nature of Income Paid to Foreign Vendors Matters Part 7 – Tax Treaty Exemptions from Withholding

A common withholding exemption is a claim under an applicable provision of an income tax treaty with the country of tax residence of the income’s beneficial owner. Such a claim must be made by the vendor on a valid Form W- 8BEN, or a Form 8233 in the case of treaty claims by individuals on … Read More

Why Nature of Income Paid to Foreign Vendors Matters Part 6 – Exemptions from Withholding

Whether an exemption from withholding under either income tax rules or an applicable income tax treaty applies depends on the character of the U.S.-source income being paid (as defined by U.S. tax rules). For example, a foreign vendor with income that is effectively connected to the conduct of a U.S. trade or business (called “ECI”) … Read More

Why Nature of Income Paid to Foreign Vendors Matters Part 5 – Unknown Source of Income

AP must also know whether or not the income being paid is U.S.-source in order to withhold and report correctly. During an audit, the IRS will request evidence supporting foreign-source payments such as contracts, invoices, expense reports and so forth. If a payment to a foreign vendor includes both U.S.- and foreign-source income and no … Read More

Why Nature of Income Paid to Foreign Vendors Matters Part 4 – Bundled Income

When an income payment is one amount that covers more than one type of income, the payment must be reasonably allocated among all types of income covered by the payment. For example, a single payment to a foreign vendor for the purchase of equipment, which is not subject to 30 percent withholding, might include shipping … Read More

Why Nature of Income Paid to Foreign Vendors Matters Part 3 – Uncategorized Income

In order for payments to foreign vendors to be timely made and correctly withheld and reported, accounts payable (AP) personnel need to know the nature of the income before payment is made, ideally before the invoice is received. Since many payments are based on the terms of the agreement, this can best be determined at … Read More

Why Nature of Income Paid to Foreign Vendors Matters Part 2 – Source of Income Rules

U.S. sourcing rules vary with the type of income being paid, as do U.S. rules for a lower rate of or exemption from withholding. In addition, a payer must correctly record the income code on Form 1042-S so that the foreign vendor may submit a correct U.S. tax return, assuming one is required. Therefore, … Read More