Do you live in the U.S. on a nonresident visa (e.g., G-4, A, or J visa)?Do you live outside the U.S. but own U.S. real estate or investments?Did you give up your green card or U.S. citizenship but maintain property or accounts in the [...]
Many self-employed foreign nationals perform consulting services in the U.S. on an infrequent basis. As such, they may not accrue enough days in the U.S. to be considered tax resident under the so-called Substantial Presence Test. Instead, these individuals are nonresidents of the U.S. [...]
Taxpayers have been subject to the new U.S. tax rules under the Tax Cuts and Jobs Act (TCJA) for almost half a year now. TCJA has changed the way qualified job-related moving expenses are treated for tax purposes. This new legislation went into effect [...]
Over the past 6 months, several major changes have had a significant impact on the tax industry. First, the Tax Cuts and Jobs Act of 2017 (TCJA) was passed in late December 2017. TCJA ushered in a new era of domestic and international corporate [...]
How Tax Reform Has Changed the Structure and Planning for Nonresident Aliens with U.S. Real Property Interests Wolf Group International Tax Director Mishkin Santa recently interviewed International Tax Attorney David Gershel to solicit his perspectives on how the Tax Cuts and Jobs Act of 2017 [...]
Founder Len Wolf 's mother visits him in his early office space. It was time. The year was 1983, and I was a young, single guy, successfully employed as an accountant with a growing, mid-size Northern Virginia defense contractor. I enjoyed my [...]
A near-record number of U.S. citizens and green card holders expatriated in calendar year 2017—5,133 as reported by the IRS[1]—and this list is widely considered to undercount the true number of expatriates. In fact, since 2010, when Congress passed the Foreign Account Tax Compliance [...]
When tax reform was passed last December, the new legislation included a requirement for certain individuals with an interest in a foreign corporation to calculate and report a Repatriation Tax on their 2017 tax returns. This tax (or the initial installment payment) was due [...]
While individuals expatriating from the U.S. often consider the income tax impacts of expatriation, few have a clear understanding of the U.S. gift and estate tax implications that their families may face should they, as a covered expatriate[1]: Make gifts or bequests to U.S. [...]
If you are an individual who owns or holds at least a 10% interest in a Controlled Foreign Corporation (CFC), you have probably spent the last 4 to 6 weeks working your CPA on how to calculate the new Repatriation Tax[1] under the Internal [...]
