BarbriSFCourseDetails
  • videocam On-Demand Webinar
  • signal_cellular_alt Intermediate
  • card_travel Tax Law
  • schedule 90 minutes

Nonresident Alien and Foreign Business Tax Compliance: Critical Tax Presence and Residency Issues

$347.00

This course is $0 with these passes:

CLE
ALL
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About the Course

Introduction

This CLE/CPE course will provide tax counsel and compliance professionals guidance on the rules, reporting requirements, and available tax planning mechanisms for U.S. nonresident alien (NRA) taxpayers and foreign businesses. The panel will discuss the impact of the One Big Beautiful Bill Act (OBBBA), offer approaches for determining taxpayer classification, identifying and reporting income subject to U.S. income tax, available exemptions, deductions, and credits in light of recent IRS compliance campaigns and tax planning tips for U.S. NRA taxpayers and foreign businesses.

Description

The OBBBA introduces changes that impact NRAs and foreign businesses, including modifications regarding tax compliance, business deductions, and attribution rules for foreign corporations. Tax professionals and advisers must have a solid understanding of the relevant rules for NRAs and non-U.S. businesses and their interplay with the OBBBA and recent Treasury and IRS guidance.

Under the OBBBA, NRAs remain ineligible for the U.S. standard deduction, continue to be taxed only on their U.S.-source income and income effectively connected with a U.S. trade or business, and may be subject to a 1% excise tax on personal cash-based remittances transferred from the U.S. to overseas recipients.

For foreign or multinational businesses, the OBBBA redefines global intangible low-taxed income and foreign-derived intangible income, Section 174 R&D expensing and deductions, bonus interest deductions under Section 163(j), and reinstates 100% bonus depreciation.

Tax professionals must carefully navigate the complexities of these tax rules and their impact on U.S. NRAs and foreign businesses.

Listen as our panel guides tax professionals and advisers in determining taxpayer status for non-U.S. citizens and businesses, challenges for U.S. citizens currently working abroad, reporting requirements and available mechanisms in light of the OBBBA, and best practices for taxpayers.

Presented By

Jill A. Helm, CPA
Manager
Baker Tilly
Burgess Raby
Principal
Raby Law Office

Mr. Raby's practice focuses on international tax matters, including planning for foreign investment into the United States, planning for United States persons investing and undertaking businesses outside the United States, ownership of foreign real estate by United States persons (FIRPTA), and ensuring that all United States reporting requirements are met, including FATCA, FBARs, and various IRS information returns. He also includes advising start-up companies and tax litigation matters, both international and domestic.

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Credit Information

  • This 90-minute webinar is eligible in most states for 1.5 CLE credits.


  • Live Online


    On Demand

Date + Time

  • event

    Thursday, January 22, 2026

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

I. Tax presence and residency rules; impact of OBBBA

II. Tax issues for non-U.S. individuals and businesses

III. Tax issues for U.S. citizens forced to stay abroad

IV. Compliance and reporting challenges for taxpayers

The panel will review these and other key issues:

  • What are the applicable tax rules for tax presence and residency of individuals and businesses?
  • What issues must be considered in light of the OBBBA?
  • How is the "substantial presence test" applied?
  • What is the impact on the foreign earned income exclusion?
  • How do you determine whether a business is considered to have a U.S. trade or business or permanent establishment?
  • How should taxpayers document positions and anticipate future audits?