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Let’s suppose we find a US trade does exist. If it doesn’t, then we’ll talk about the FDAP a little bit later in the presentation. If a non-US person engages in US trade or business activities, then the next question is: Is the income that he derives connected to these US trade or business activities, […]
Let’s suppose it is indeed US-source income; then the next question that we have to deal with is whether this non-US person engages in US trade or business activities. Just to repeat myself, if it is not a US-sourced income, generally speaking, it’s not taxable; but you see here and there that in order to […]
Once we have established that this is a non-US Person, the next question is: Is this person getting a US-source income? This is a critical question of huge importance and huge complexity. Why is it important? Because non-US Persons generally, (there are exceptions) are taxed on their US-sourced income. This means that if the income […]
The first question, when a client comes to the office, should be: “Is it a US Person?” I say ‘it’ because a client may not be only an individual but also a corporation, a trust or an estate. This question may not be that easy to answer, as it may appear in the beginning. Let’s […]
The 2020 FBAR conversion rates are highly important in US international tax compliance. The 2020 FBAR and 2020 Form 8938 instructions both require that 2020 FBAR conversion rates be used to report the required highest balances of foreign financial assets on these forms (in the case of Form 8938, the 2020 FBAR conversion rates is […]