Requesting Guidance for Treaty Nonresidents

Attorney Michael Karlin co-published an article in Tax Notes titled "Requesting Guidance for Treaty Nonresidents." 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. The authors requested guidance and confirmation from the U.S. Treasury Department 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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