This webinar will guide tax professionals and advisers on the latest IRS examination guidance and state tax law issues regarding taxpayer residency. The panel will discuss federal and state tax residency rules, residency and allocation matters, U.S. income tax treaties, available tax planning techniques, managing nonresident audits, and overcoming state regulatory challenges. Advising taxpayers on issues relating to residency has become even more cumbersome. The IRS LB&I unit has issued examination guidance focused on taxpayer residency and the application of U.S. income tax treaties. State tax residency rules and an increase in state audits and enforcement require tax professionals to become knowledgeable of new state residency and allocation issues to implement effective tax planning strategies for taxpayers.
Learning Objectives
• Recognizing the importance of both citizenship and residence in determining tax liabilities of individuals
• Determine common residency provisions and tiebreakers for dual residents
• Understand California tax residency rules and guidelines and New York domicile test and primary factors in determining tax residency
• Identify dual-residency issues with non-personal income tax states
Major Topics
• Federal residency rules
• IRC Section 7701(b) and substantial presence
• Tax treaty residency
• Exceptions based on facts and circumstances
• Recent IRS examination guidance
• State regulatory challenges; new allocation and residency issues
• California residency rules and guidelines
• Florida and other non-personal income tax states
• Managing nonresident audits
• Tax planning techniques and best practices for dual-resident taxpayers and multistate companies
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