Nonresident Tax Reporting: Who, What, and How?, by Frank Agostino, Esq. and Eugene Kirman, Esq.

Unlike citizens and resident aliens, who are taxed on their worldwide income, nonresident aliens are taxed only on their U.S. source income and on income effectively connected with the conduct of a U.S. trade or business. Non-immigrant visa holders are often nonresident aliens for U.S. income tax purposes. Non-immigrant visa holders include, among others, A-1/-2/-3 diplomats and foreign government officials, B-1 business travelers, B-2 visitors, F-1/-2 students, H-1B persons in specialty occupations, H-2A temporary agricultural workers, H-2B temporary non-agricultural workers, H-3 trainees or special education visitors, J-1/-2 exchange visitors, M-1/-2 students, and Q-1 international cultural exchange participants. …

Understanding & Challenging IRS Form 4340, Certificate of Assessment, Payments, and Other Specified Matters, in Civil Tax Controversies, by Frank Agostino, Esq. and Edward N. Mazlish, Esq.
In civil proceedings between the Internal Revenue Service (“IRS”) and taxpayers involving assessments and collections of taxes, the tax professional needs to understand what information the IRS must introduce into evidence to support its claim. Understanding how to challenge IRS taxpayer transcripts is critical to a proper defense of the taxpayer. The tax professional must understand how the IRS stores its information and how it attempts to introduce that information into evidence if the taxpayer litigates in Court – which is usually by way of introducing the Form 4340, Certificate of Assessment, and Payments, and Other Specified Matters, into evidence. This article discusses how the IRS complies with its statutory mandate to keep a record of its assessments; how the IRS uses that record of assessments to create Form 4340 for litigation; and how to challenge Form 4340 in civil proceedings with the IRS. …
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