Tax & Accounting Blog

U.S. or Foreign Person Part 3: Foreign Person

U.S. or Foreign Person Part 3: Foreign Person

Individuals who are foreign persons include all non-U.S. citizens who are neither green-card holders nor meet the 183-day substantial presence test (called nonresident aliens). Nonresident aliens also include individuals who meet the 183-day substantial presence test for the calendar year but who are also residents of a tax treaty country (called dual residents) who make an … Read More

U.S or Foreign Person Part 2: U.S. Person

U.S or Foreign Person Part 2: U.S. Person

Individuals who are U.S. persons include U.S. citizens and non-U.S. citizens who are resident aliens for U.S. federal tax purposes. U.S. citizens and resident aliens are subject to withholding and reporting on their worldwide income even when they live and work outside the U.S. U.S. citizens include: Individuals born in the U.S. Individuals born outside of … Read More

onesource

Fun with International Tax Provision Issues

 When I was young and naïve, I overheard a seasoned practitioner remark: “If tax provisions are fun…then dealing with the international pieces of the provision is the most fun you can have.”  I’m now neither young nor naïve and I recognize the sarcasm in the remark.  However, I do believe the issues are interesting and, … Read More

Is Minnesota Ready for Tax Reform?

Is Minnesota Ready for Tax Reform?

This was the main topic of discussion amongst 400+ tax professionals at TEI’s 29th Annual President’s Seminar in Minneapolis last week.  In his opening address, Myron Frans, Minnesota Commissioner of Revenue addressed the group on the state’s complex tax policy and unique challenges, including demographic and economic changes impacting tax revenue. He emphasized that over time, the mix of … Read More

U.S or Foreign Person Part 1

U.S or Foreign Person Part 1

In order for payers (called withholding agents because of their obligation to withhold taxes) to withhold and report income payments appropriately, they must determine whether the beneficial owner of the income is a U.S. person or a foreign person. The broad definition for the term, withholding agent, includes anyone who “has control, receipt, custody, or … Read More