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In CCA 20122008, the Chief Counsel’s Office ruled that compensation earned by green card workers while working for the Italian government in the United States is not exempt from the federal income tax pursuant to an 1878 U.S.-Italy consular convention on the basis that greencard holders can not be consular offices, nor under the 1984 U.S.-Italy income tax convention if Italy has the primary right to tax the worker, since the U.S. provides for foreign tax credits
France, Germany, Italy, Spain, United Kingdom, USA
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February 15 2012
Congress, in 2010, enacted a new set of rules on the required reporting and withholding with respect to foreign financial accounts and nonfinancial foreign entities in Pub. L. No. 111-147, 501 (2010)(the “HIRE ACT”
