Issue How can treaties between the United States and other countries affect the income of foreign nationals in the United States? Facts Bhutta, a citizen of Pakistan and a foreign medical school graduate, entered the United States in 2009 to…
Issue Who qualifies as a real estate professional for tax purposes? More specifically, how does a taxpayer establish that he or she materially participate in rental activities, so that the rentals become non-passive, and any losses can be used without…
Issue What is the allocation of partnership liabilities and the tax implication of a foreclosure? Related Tax Rule or Regulation Internal Revenue Code Section 465 Internal Revenue Code Section 704 Internal Revenue Code Section 731 Internal Revenue Code Section 752…