Tax & Accounting Blog

Indian Finance Bill May Have Chilling Effect on Investment

Indian Finance Bill May Have Chilling Effect on Investment

With economic growth running at an annual pace of more than 8 percent, the attraction of investing in India is obvious. And, for many companies, investing is India is no longer optional. However, recently  proposed  legislation may force companies to reevaluate their investment posture. Governments around the world facing budgetary crises are tightening transfer pricing regulations and strengthening … Read More

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

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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