I.R.C. 873 – Foreign Tax Status Information Group (FTSIG)

U.S. Supreme Court Justice Sandra Day O’Connor (SDO) Acknowledges applicability of 26 U.S.C. 873 to “nationals of the United States”

By ftsig-admin | April 9, 2026

“Indeed, we fail to see how New York’s disregard for the residence of the alimony recipient does anything more than point out potential inequities in the operation of § 631(b)(6). Certainly, the concept of income splitting works when both former spouses are residents of the 313*313 same State, because one spouse receives a tax deduction corresponding to…