Prior to the enactment of Sec 864(c)(8) as part of the TCJA-2017, a foreign partner could sell an..
In response to the pandemic, the IRS has waived the residency and presence tests that apply for..
The IRS provided relief to nonresident aliens and foreign corporations affected by the novel..
Every US person with financial interest or signature authority over a foreign financial account(s),..
The substantial presence test is the test used to determine if a nonresident alien (non-US citizen..
Recent changes may eliminate some of the deemed distributions from controlled foreign corporations..
With the IRS finalizing the rules related to the foreign-derived intangible income (FDII) deduction..
Individuals who are US citizens and those who are considered domiciled in the US are subject to US..
The IRS has had a long-standing concern about taxpayers who try to use debt rather than stock..
