Description

<p>As a boutique international tax firm, we&rsquo;re finding international tax issues arising for individuals and companies of all sizes. Many of them never thought they&rsquo;d have any cross-border activities. As many of our clients are CPA and law firm across the US, we thought it might be helpful to do a series of discussions on International Tax for the Non-Specialist. They are overviews designed to assist practitioners and taxpayers identify issues. The overviews dive into some level of detail, but we envision separate sessions to more fully explain various technicalities.</p>

<p>This discussion is #4 in the series following:

#1 on tax residency and foreign financial account disclosures [FBAR / FinCen 114 / Form 8938];

#2 on earning foreign income and an employee being transferred to a foreign affiliate; 

#3 on the anti-deferral rules of Subpart F and identifying a controlled foreign corporation).</p>

<p>The primary focus on this presentation is an overview of how the US taxes the income of Nonresidents. This includes, but is not limited to:</p>

<p>1. Taxation differences between Residents and Nonresidents.<br />

2. How to identify whether an individual is a Resident versus Nonresident.<br />

3. Identifying types of Nonresident income the US may tax.<br />

4. Different filing status (e.g., Married Filing Jointly).<br />

5. Tax calculation (e.g., gross versus net; what deductions are Nonresidents able to claim).<br />

6. Overview of Resident taxation and how a non-US citizen may become a US tax resident.<br />

7. FDAP versus Effectively Connected Income.<br />

8. When there is withholding on gross income versus a return filed on net income.<br />

9. Compliance factors.<br />

10. Issues related to whether there is a US trade or business.<br />

11. As relevant, state tax issues are embedded throughout.</p>

<p>&nbsp;</p>

<p>Course key Concept: <b>International tax, Individual income tax, Resident Alien, Substantial presence test, Nonresident Alien Green Card, US trade or business, Effectively connected income, W-8BEN, Information returns, FinCEN 114 / FBAR, 8938, 5471 8865, 8858, 3520, 8621, 926, FDAP.</b></p>