Liliana Menzie and Michael J.A. Karlin, in “Request for Guidance Regarding Dual Residents under Treasury Regulations Section 301.7701(b)-7 Who Are Treated as Nonresident Aliens of the United States,” an article published in both Tax Notes and the California Tax Lawyer, request guidance and confirmation from the IRS that a dual resident taxpayer should be treated as a nonresident alien in calculating the individual’s U.S. income tax liability and for all purposes of the code, including U.S. information reporting requirements.

According to Mr. Karlin’s website, the article will be available on that website after publication and until then will be available on request from the author.

Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.