Investing

Financial Institutions: The Challenge. Compelled “U.S. person” status

March 7, 2025

1. Background Although the Internal Revenue Code properly recognizes your right to choose a nonresident alien status and be unenumerated,…

Foreign Partner Withholding Under I.R.C. 1446

July 21, 2024

This article proves that there is no foreign partner withholding within a partnership where one or more other partners are…