Tax Analysts contains news, analysis, and commentary on nonresident taxation of wage, sales, and investment income for individuals, personal property; corporations, and passthrough entities, including international and U.S. state issues; U.S. effectively connected income as defined in IRC section 864(c); passive income such as interest, dividends, rent, and royalties; transportation income; and the substantial presence test under IRC section 7701(b) (26 U.S.C. 7701(b)). Information reporting obligations are also addressed.
Guidance is provided on VAT payments to nonresidents of the taxing jurisdiction, allocation and apportionment of deductions, IRC section 871(a)(2) (26 U.S.C. 871(a)(2)) taxation of capital gains of nonresident aliens, the IRC section 871(b) and IRC section 882 definitions of engaged in a trade or business; definitions of residence for international and U.S. state tax purposes.
Recurring issues in nonresident taxation include taxation of gambling winnings; taxation of income to athletes and entertainers who perform in multiple jurisdictions, including equal protection arguments; European Union law on freedom of movement for workers; the Tax Injunction Act (28 U.S.C. 1341) (see, e.g., Direct Marketing Association v. Brohl) and taxation of remote sales (see, e.g., Quill Corp. v. North Dakota, 504 U.S. 298 (1992)) and online sales. Commuter taxes among U.S. states and cities are another recurring issue, recently raised in D.C. and Scranton, Pennsylvania.
Tax Analysts consistently and promptly publishes all relevant developments regarding taxation of nonresident aliens. To stay up to date on all tax-related topics, subscribe to Tax Notes Today Federal.