If a U.S. resident makes a payment to a foreign resident, that payment may be subject to withholding at 30%. Although there are many provisions in the Internal Revenue Code that may reduce—or even eliminate—that withholding, those rules are extremely complex. Moreover, the failure to withhold will result in a tax liability for the U.S. payor which the IRS will try to collect. This program will detail the withholding rules and the exceptions so that U.S. payors of income to foreign persons will sleep better at night!
Robert Misey leads the International Department for the law firm of Reinhart Boerner Van Deuren and is a former trial attorney for the IRS Chief Counsel (International) in Washington, DC. Robert is Chair of the International Tax Committee for the ABA and a member of the bar in California, Wisconsin, and the District of Columbia. He is also the author of the book, A Practical Guide to U.S. Taxation of International Transactions and Federal Taxation: Practice and Procedure.