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Non-Resident Alien Withholding: We raised with the IRS concerns that they were going to commence audits of non-financial institutions related to documentation (Form W8 series), withholding, and reporting (Form 1042S) compliance related to items such as vendor payments and royalties without involving the community. If the new provisions are enacted, the non-resident alien could continue to be a qualifying shareholder. His experience has focused on private client, middle market and non-resident alien business models. |
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