Sep 7, 2015

Requesting Guidance For Treaty Nonresidents

On September 7, 2015, Michael Karlin co-published "Requesting Guidance For Treaty Nonresidents," with Liliana Menzie of DLA Piper in Tax Notes. This report was sponsored by the California Bar Association and presented to various policymakers and government officials. It identified several problems with the IRS’s apparent position that dual resident taxpayers are required to file U.S. information returns as resident aliens. Michael and Liliana requested guidance and confirmation from the Treasury that a dual resident taxpayer should be treated as a nonresident alien in calculating the individual’s U.S. income tax liability and for all purposes of the code, including U.S. information reporting requirements.

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