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Nonresident Alien and Foreign Business Tax Compliance: Critical Tax Presence and Residency Issues

Key Reporting and Compliance Challenges, Protective Filings, Relief Under Rev. Proc. 2020-20 and Rev. Proc. 2020-27

Recording of a 90-minute premium CLE/CPE webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
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Conducted on Thursday, July 16, 2020

Recorded event now available

or call 1-800-926-7926

This CLE/CPE course will guide tax professionals and advisers on critical tax presence and residency issues for individuals and businesses stemming from COVID-19.


The health risks of COVID-19 and federal and local government responses create tax presence and residency issues for businesses and individuals. Tax professionals and advisers must have a solid understanding of the relevant rules for nonresident aliens and non-U.S. businesses and their interplay with recent Treasury and IRS guidance in light of the coronavirus pandemic.

On Apr. 21, 2020, in response to COVID-19 and travel and other disruptions, Treasury and the IRS provided guidance, specifically Rev. Proc. 2020-20 and Rev. Proc. 2020-27, along with “Frequently Asked Questions” issued by the IRS, to mitigate potential negative tax consequences for individuals and businesses, including with respect to residency, the foreign income exclusion, and U.S. trade or business and permanent establishment issues.

Listen as our panel guides tax professionals and advisers in determining taxpayer status for non-U.S. citizens and businesses, challenges for U.S. citizens currently working abroad, reporting requirements and available mechanisms in light of recent IRS guidance, and best practices for taxpayers.



  1. Tax presence and residency issues created by COVID-19
  2. Tax issues for non-U.S. individuals and businesses
  3. Tax issues for U.S. citizens forced to stay abroad
  4. Compliance and reporting challenges for taxpayers


The panel will review these and other key issues:

  • What is the impact of COVID-19 on the tax presence and residency of individuals and businesses?
  • How does Rev. Proc. 2020-20 impact the application of the "substantial presence test"?
  • How does Rev. Proc. 2020-27 impact the foreign earned income exclusion?
  • How do IRS “Frequently Asked Questions” impact the determination of whether a business is considered to have a U.S. trade or business or permanent establishment?
  • How should taxpayers document positions and anticipate future audits?


Azebu, Lauren
Lauren Azebu

Steptoe & Johnson

Ms. Azebu focuses on taxation issues for both domestic and foreign clients. Her experience includes planning and...  |  Read More

Tractenberg, Beth
Beth D. Tractenberg

Steptoe & Johnson

Ms. Tractenberg guides high-net-worth individuals, families, and fiduciaries in international and domestic estate...  |  Read More

Varma, Amanda
Amanda P. Varma

Steptoe & Johnson

Ms. Varma advises multinational businesses, family offices, and high-net-worth individuals on US federal income tax...  |  Read More

Access Anytime, Anywhere

Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

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