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 ...
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U.S or Foreign Person Part 2: U.S. Person
1099, ONESOURCE, Tax Information Reporting, W-8 & W-9 Foreign Reporting, Withholding Management 0 CommentPosted on May 3, 2012
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 ...
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U.S or Foreign Person Part 1
1099, ONESOURCE, Tax Information Reporting, W-8 & W-9 Foreign Reporting, Withholding Management 0 CommentPosted on May 1, 2012
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 ...
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Residency for Tax Treaty Purposes for Individuals Part 4: The Tax Expatriation Rule
1099, ONESOURCE, Tax Information Reporting, W-8 & W-9 Foreign Reporting, Withholding Management 0 CommentPosted on April 27, 2012
Tax code Sections 877 and 877A (the exit tax) impose special provisions on certain U.S. citizens who terminate their citizenship and long-term green-card holders who lose their status through abandonment (whether or not intentional) or revocation provided they meet certain criteria. As a result, most tax treaties include provisions limiting the eligibility ...
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Residency for Tax Treaty Purposes for Individuals Part 3: The Savings Clause Exception
1099, ONESOURCE, Tax Information Reporting, W-8 & W-9 Foreign Reporting, Withholding Management 0 CommentPosted on April 25, 2012
Because the United States imposes worldwide taxation on its citizens and immigrants (popularly called green-card holders), all U.S. tax treaties include a provision commonly referred to as a savings clause because it saves the right of the U.S. to tax its citizens and residents wherever they reside in the world. For ...
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Residency for Tax Treaty Purposes for Individuals Part 2: Eligibility for Treaty Benefits
1099, ONESOURCE, Tax Information Reporting, W-8 & W-9 Foreign Reporting, Withholding Management 0 CommentPosted on April 23, 2012
Eligibility for tax treaty benefits in the first instance is based on an individual's tax residency status (not citizenship) in the treaty country. The timing of tax residency in the treaty country varies with the treaty article providing the benefit. Most treaty benefits require an individual to be a tax resident of ...
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Partners and Details Firming around FATCA
1042-S, 1099, Document and WorkFlow Management, FATCA, Global Tax Compliance, Information Reporting for Wealth Management, ONESOURCE, Tax Information Reporting, TIN Compliance, Trust Tax, W-8 & W-9 Foreign Reporting, Withholding Management 0 CommentPosted on April 11, 2012
Foreign financial institutions and governments might initially have groaned when the U.S. Congress passed the Foreign Account Tax Compliance Act in March 2010, but it looks like at least some of them are starting to come around. In February, the U.S. Treasury announced it had partnered with five European nations ...
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Registration for April Nonresident Alien and Foreign Vendor Tax Compliance Training Nearly Closed
1099, ONESOURCE, Tax Information Reporting, TIN Compliance, W-8 & W-9 Foreign Reporting, Withholding Management 0 CommentPosted on April 10, 2012
Registration for April's Nonresident Alien and Foreign Vendor Tax Compliance Training is nearly closed. The training, which takes place April 24 -27,  at the Hyatt Regency in Cambridge, Massachusetts, has nearly forty-five sessions divided into a two-day lecture track and a two-day software track, allowing attendees to register for all four days ...
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New Cost Basis Rules May Be Lost on Many
1042-S, 1099, 6050W, Cost-Basis Reporting, Information Reporting for Wealth Management, ONESOURCE, Tax Information Reporting, TIN Compliance, Trust Tax, W-8 & W-9 Foreign Reporting, Withholding Management 1 CommentPosted on April 9, 2012
With taxpayers in the throes of planning their 2011 income tax returns, now’s a good time to remind filers not to overlook new cost basis reporting rules governing securities sales. In the past, they had the option of specifying which shares they sold when computing their cost basis. But as of ...
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Treaty Exemptions for Business Profits – Part 5: A Fixed Place of Business
1099, ONESOURCE, Tax Information Reporting, W-8 & W-9 Foreign Reporting, Withholding Management 0 CommentPosted on April 4, 2012
In order for an enterprise to have a fixed place of business, the place of business must be a building or physical location. The premises need not be owned or leased by the enterprise nor used exclusively by the enterprise. It is enough that the space is at the constant ...
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Learn the Latest in Nonresident Alien and Foreign Vendor Tax Compliance
1099, FATCA, Information Reporting for Wealth Management, ONESOURCE, Tax Information Reporting, W-8 & W-9 Foreign Reporting, Withholding Management 0 CommentPosted on April 2, 2012
Paula N. Singer, Esq., Thomson Reuters practice leader, will present a number of sessions on nonresident alien and foreign vendor tax compliance this spring during webcasts, training seminars and trade shows. Murthy Law Firm’s Corporate Telecast On April 4, 2012, Paula will participate in Murthy Law Firm’s corporate telecast, U.S. Tax Issues for ...
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Treaty Exemptions for Business Profits – Part 3: Treaty Exemptions from Withholding
1099, ONESOURCE, Tax Information Reporting, W-8 & W-9 Foreign Reporting 0 CommentPosted on March 26, 2012
A foreign entity may claim a treaty-based exemption from NRA withholding by submitting a Form W-8BEN with the treaty claim described in Part 2 and the income for which an exemption is being claimed described on line 10. To be valid, the Form W-8BEN must include the entity’s U.S. Employer ...
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Withholding on U.S. Business Income of Foreign Vendors – Part 2: Claiming Exemption from Withholding on Effectively Connected Income
1099, ONESOURCE, Tax Information Reporting, W-8 & W-9 Foreign Reporting, Withholding Management 0 CommentPosted on February 27, 2012
A foreign enterprise that is engaged in a U.S. trade or business during the tax year may request an exemption from NRA withholding on its Effectively Connected Income (ECI) that is identified on line 9 of a valid Form W-8ECI presented to the payer prior to payment (unless an exemption ...
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Information Reporting on Form 1042-S: A New Challenge for Accounts Payable
1099, FATCA, ONESOURCE, Tax Information Reporting, W-8 & W-9 Foreign Reporting, Withholding Management 0 CommentPosted on February 15, 2012
Reporting income and taxes withheld on payments made to corporate vendors recently became more challenging for accounts payable (A/P) departments of both for-profit and not-for-profit organizations with the new IRS compliance focus on payments to nonresident alien individuals, foreign entities and foreign governments (collectively, foreign persons). A/P departments familiar with the ...
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