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Expatriate

Regs on withholding where foreign person disposes of USRPI reflect Path Act changes

Regs on withholding where foreign person disposes of USRPI reflect Path Act changes

TD 9751: PATH Act Changes to Section 1445. IRS has issued final and temporary regs on the taxation of, and withholding on, foreign persons upon certain dispositions of, and distributions with respect to, U.S. real property interests (USRPIs); the regs reflect changes made by the Protecting Americans from Tax Hikes Act of 2015 (the PATH […]

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Tax Court – German taxpayer was subject to regular U.S. income tax and covered expatriate tax

Tax Court – German taxpayer was subject to regular U.S. income tax and covered expatriate tax

Topsnik, 146 TC No. 1 The Tax Court has held that a taxpayer with connections to Germany, including a German passport, who had a U.S. green card for many years, was not a German resident, and was therefore subject to U.S. taxation as a nonresident. It also found that he was subject to the Code […]

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Proposed regs detail transfer tax on covered gifts and bequests from covered expatriates

Proposed regs detail transfer tax on covered gifts and bequests from covered expatriates

Preamble to Prop Reg 09/09/2015, Prop Reg § 28.2801-1, Prop Reg § 28.2801-2, Prop Reg § 28.2801-3, Prop Reg § 28.2801-4, Prop Reg § 28.2801-5 , Prop Reg § 28.2801-6 , Prop Reg § 28.2801-7 IRS has issued proposed regs on the tax under Code Sec. 2801 on U.S. citizens and residents who receive gifts […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney