Nonresident Alien and Foreign Business Tax Compliance: Critical Tax Presence and Residency Issues
Key Reporting and Compliance Challenges, Protective Filings, Relief Under Rev. Proc. 2020-20 and Rev. Proc. 2020-27
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will guide tax professionals and advisers on critical tax presence and residency issues for individuals and businesses stemming from COVID-19.
Outline
- Tax presence and residency issues created by COVID-19
- Tax issues for non-U.S. individuals and businesses
- Tax issues for U.S. citizens forced to stay abroad
- Compliance and reporting challenges for taxpayers
Benefits
The panel will review these and other key issues:
- What is the impact of COVID-19 on the tax presence and residency of individuals and businesses?
- How does Rev. Proc. 2020-20 impact the application of the "substantial presence test"?
- How does Rev. Proc. 2020-27 impact the foreign earned income exclusion?
- How do IRS “Frequently Asked Questions” impact the determination of whether a business is considered to have a U.S. trade or business or permanent establishment?
- How should taxpayers document positions and anticipate future audits?
Faculty
Lauren Azebu
Attorney
Steptoe & Johnson
Ms. Azebu focuses on taxation issues for both domestic and foreign clients. Her experience includes planning and... | Read More
Ms. Azebu focuses on taxation issues for both domestic and foreign clients. Her experience includes planning and structuring corporate transactions, FATCA compliance, and the Swiss-US Non-Prosecution Agreement program. Ms. Azebu also is actively involved in Steptoe's pro bono program, and has assisted several clients in settling tax issues with the IRS and state tax agencies.
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Beth D. Tractenberg
Partner
Steptoe & Johnson
Ms. Tractenberg guides high-net-worth individuals, families, and fiduciaries in international and domestic estate... | Read More
Ms. Tractenberg guides high-net-worth individuals, families, and fiduciaries in international and domestic estate planning, contested matters, estate administration, the creation and advising of exempt organizations, and drafting and negotiating prenuptial agreements. Ms. Tractenberg, who heads Steptoe’s Private Clients practice, provides comprehensive tax, personal, and business advice to families, working closely with their family offices and other advisers. Drawing on her tax and trusts and estates experience, she serves clients as a personal and family adviser on numerous business, management, and related personal issues, including issues involving real estate and business holdings in the United States and abroad. Ms. Tractenberg has extensive experience advising international clients on cross-border and pre-immigration planning, gifting, estate planning, and other tax issues. She frequently assists in resolving business disputes and sensitively guides succession planning across generations of family members.
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Amanda P. Varma
Partner
Steptoe & Johnson
Ms. Varma advises multinational businesses, family offices, and high-net-worth individuals on US federal income tax... | Read More
Ms. Varma advises multinational businesses, family offices, and high-net-worth individuals on US federal income tax matters, with particular focus on international tax planning and controversies. She counsels both US- and foreign-owned businesses across a variety of industries, regularly advising on the US tax consequences of cross-border investments, reorganizations, business restructurings, acquisitions, and financings.
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