Taxation of Gifts From Foreign Persons

Generally, nonresident aliens (“NRAs”) are only subject to tax on income from U.S. sources and income received in connection with the conduct of a trade or business within the U.S. However, in certain circumstances, an NRA may also be subject to wealth transfer tax (i.e., estate and gift tax). This memorandum presents an overview...

Read More

Increased Penalties Possible Under the 2014 Offshore Voluntary Disclosure Program

The Internal Revenue Code requires U.S. citizens and permanent residents to report worldwide income, foreign bank accounts and foreign financial assets regardless of where they are located. This is not a new requirement, yet many U.S. persons have historically failed to satisfy these reporting requirements. To address this problem, s...

Read More