International Tax and Global Mobility

Residency, expatriate relief, foreign reporting, and withholding for cross-border individuals and businesses.

Key sections and concepts

Section 7701(b): Resident alien definition
Sets the green card and substantial presence tests.
Section 871: Nonresident alien income
Taxes U.S.-source income of nonresident aliens.
Section 877A: Expatriation tax
Applies a mark-to-market exit tax to covered expatriates.
Section 894: Income under treaties
Coordinates the Code with income tax treaties.
Section 901: Foreign tax credit
Allows a credit for qualifying foreign income taxes.
Section 904: Foreign tax credit limitation
Limits the credit by category of income.
Section 911: Foreign earned income exclusion
Excludes qualifying foreign earned income and housing amounts.
Section 951A: Tested income of CFCs
Taxes U.S. shareholders on certain CFC income, formerly known as GILTI.
Section 1291: PFIC taxation
Sets the excess distribution regime for PFIC investors.
Section 1441: Withholding on nonresidents
Requires withholding on certain payments to nonresident aliens.
Section 1446: Foreign partner withholding
Requires withholding on income allocable to foreign partners.
Section 1471: FATCA withholding
Imposes withholding on certain payments to foreign financial institutions.
Section 6038: Foreign corporation reporting
Underlies Form 5471 information reporting.
Section 6038D: Foreign financial assets
Requires Form 8938 reporting by specified individuals.

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