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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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State Nonresident Income Tax On Law Partner’s Income Not Deductible On Schedule E

State Nonresident Income Tax On Law Partner’s Income Not Deductible On Schedule E

Cutler, TC Memo 2015-73   The Tax Court has held that state nonresident income taxes paid by a lawyer on his law firm’s income sourced in four states can’t be deducted on Form 1040, Schedule E and aren’t deductible in arriving at adjusted gross income (AGI). These taxes may only be claimed below-the-line as itemized […]

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IRS updates list of countries with which it has nonresident alien interest reporting agreements

IRS updates list of countries with which it has nonresident alien interest reporting agreements

Rev Proc 2014-64, 2014-53 IRB   IRS has issued a Revenue Procedure that updates two lists of countries with which the U.S. has in effect an agreement that requires payors to report interest paid to nonresident alien individuals who are residents of the other country. One list is of countries with which the U.S. has […]

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Lawful permanent resident couldn’t “informally” abandon his status to avoid U.S. tax

Lawful permanent resident couldn’t “informally” abandon his status to avoid U.S. tax

Gerd Topsnik, (2014) 143 TC No. 12 The Tax Court has held that an individual was a lawful permanent resident (LPR) – i.e., a resident alien taxable on his worldwide income – rejecting the individual’ss argument that he had “informally” abandoned his status as an LPR in prior years. Click here for the Opinion of […]

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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