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Foreign Taxpayers

Note:  There are dozens of articles located in the Foreign Taxpayer section of Tax Class and the Gift-Tax section of Estate Planning.

Tax Articles and Publications

January, 2009 IRS Fact Sheet on Foreign Housing - A summary of the rules involving the foreign housing exclusion.

December, 2008 IRS Publication 54 - A comprehensive guide for U.S. taxpayers working and living abroad.

May, 2008 Newsletter: Foreign Bank Accounts - Tax and reporting issues surrounding a financial interest in a foreign financial account..

October, 2006 Lecture Outline: Recent Experiences with Audits of Overseas Taxpayers and Foreign Accounts - Strategies to consider when defending overseas taxpayers in audits involving foreign-source income and foreign bank accounts.

December, 2006 Newsletter: Update: Foreign Earned Income Exclusion, an outline of recent tax-law changes.

October, 2006 Newsletter: IRS Crackdown on Obscure International Entertainers

September, 2006 Newsletter: A Tax Haven for Rock Stars

August, 2006 Newsletter: Deducting International Business Travel

February, 2005 Newsletter: Strict Limits on Foreign Profits Tax Break

Non-Resident Alien (NRA) Investment in U.S.

Investing in the United States Can Be Very Expensive! (promotional material)

Tax Consequences of Foreign Investments in U.S. Real Property

When Does a Foreign Citizen Become a U.S. Resident for Income Tax Purposes?

Are You a Resident for U.S. Tax Purposes?

Hot Topics January, 2002- Memorandum Regarding Tax Planning Opportunities for Foreign Consultants Working in the U.S.

Are your gains from the sale of stock taxable?  Check out the Foreign Taxpayer's Tax Class, which contains a number of foreign-tax FAQ's from the Tax Prophet's San Francisco Examiner newspaper column

Taxation of U.S. Settlement Proceeds Received by a Non-Resident Alien - A memo that discusses how intellectual property rights are taxed when a U.S. company violates a foreigner's copyright and a lawsuit is brought in the U.S.

Memo Regarding U.S. - Swiss Tax Issues in the formation and operation of a Swiss Company doing business in the United States. Generally applicable to any foreign company doing business in the U.S.

Memo on U.S. and California Withholding Tax Issues involving the Repatriation of Non-Real Estate Assets and Funds to a Foreign Taxpayer.

Memo on When a Foreign Company is Engaged in a Trade or Business in the U.S. and, therefore, subject to U.S. income taxes on its business operations. These issues are critical to those selling products or services in the U.S.


U.S. Estate and Gift Taxes for NRA

Hot Topics October, 2001 - Foreign Taxpayers Beware: U.S. Estate and Gift-Tax Law Can Hit Wallet Hard

The application of U. S. transfer (estate and gift) taxes  to non- U. S. taxpayers.

  IRS Notice 97-37 contains the filing and reporting requirements for Foreign Trusts and for recipients of Foreign Gifts.

1996 Tax Law Changes Affecting Foreign GIFTS

Comparing a Gift of Stock by a Foreign Person to an Individual vs. a Foreign Trust

Estate and Gift Transactions Involving Foreign Taxpayers


U.S. Taxpayers Living Abroad (Expatriates)

  Tax Planning for Expatriates (U. S. Taxpayers Working Overseas) - Articles dealing with the earned income credit and other issues facing U.S. taxpayers working abroad.  Located in the Tax Class Section.

Expatriation Taxation -- Not Just for Rich Tax Dodgers!


Foreign Trusts and Tax Havens

Advantages of Forming a Foreign Trust

Foreign tax-haven countries are  under under attack by the U.S. and Europe.  Is your secret bank account about to become public?  Read the following Hot Topic articles:

August, 2000 - The Demise of the Off-Shore Tax Havens, part 2

Off-shore Asset Protection  took a major hit by the Ninth Circuit Court of Appeals.  Read August and September, 1999 Hot Topics - The Asset Protection Industry, an Expensive and Wasteful Exercise in Wishful Thinking - parts 1 and 2.

Reporting Requirements for Foreign Trusts: Check out the summary of tax reporting requirements and penalties in the July, 1998 Hot Topics article, Off-Shore Asset Protection Trusts - Part 1. Also, IRS Notice 97-34, which discusses the foreign trust and gift reporting rules, has been reproduced in full. Also, check out Off-Shore Asset Protection Trusts - Part 2.

1996 Tax Law Changes Affecting Foreign TRUSTS

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