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Non-Resident Aliens Internal Revenue Code (IRC) Internal Revenue Service

Rivkin Radler LLP

Taxing A Foreigner’s Sale of a Partnership Interest – Déjà Vu All Over Again

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There is no denying that many parts of the Code are complex and, in some cases, too obscure for many “laypersons” to comprehend. Over time, this reality spawned the need for advisers who are both knowledgeable and experienced...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part III – Code...

Foster Garvey PC on

This third installment of my multi-part series on Subchapter S is focused on a single Code Section, namely IRC Section 1361(b)(1)(C) and the ineligibility of nonresident aliens as shareholders of Subchapter S corporations....more

Troutman Pepper

FIRPTA and Publicly Traded Corporations

Troutman Pepper on

On May 19, 2023 the Internal Revenue Service (IRS) released AM 2023-003 (the Memo or GLAM) holding that the Foreign Investment in Real Property Tax Act’s (FIRPTA’s) 5% publicly traded exception (the 5% exception) applies at...more

McDermott Will & Emery

Globally (Not So) Mobile Employees: Taxation of RSU Equity Awards in a COVID-19 World

McDermott Will & Emery on

The rules relating to the US taxation of restricted stock units (RSUs) in an international context are often complex and sometimes uncertain. This On the Subject explores how COVID-19-related travel restrictions affect the US...more

Fenwick & West LLP

IRS Filing and Reporting Requirements for ISO Exercises and ESPP Stock Transfers for 2020

Fenwick & West LLP on

This client alert is intended to remind you of certain year-end reporting requirements under Section 6039 of the Internal Revenue Code of 1986, as amended (the Code), with respect to stock issued to employees (or former...more

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