georgia nonresident withholding affidavit

The Revenue Department has informally indicated this may be correct and is studying the issue.D. Meet domestic and foreign nonresident partner withholding requirements. Under Reg. We will be looking into this with the utmost urgency, The requested file was not found on our document library. Note this will create some real practical difficulties for fiscal year entities. The taxpayer has no statute of limitations protection (or perhaps a seven year statute of limitations under O.C.G.A. Before sharing sensitive or personal information, make sure youre on an official state website. Single, Married Filing Jointly, Married. One of the most interesting aspects of O.C.G.A. . Before sharing sensitive or personal information, make sure youre on an official state website. To the extent of gain (i.e., boot), presumably this will be subject to withholding. Delaware permits companies which limit their instate activity to receipt of a passive investment income ("Passive Investment Companies" or "PICs") to pay no income tax on the earnings from these activities. Nonresidents include individuals, trusts, partnerships, corporations, limited liability companies, limited liability partnerships, and unincorporated organizations. The Q&A indicate the common sense net proceeds means amounts paid to Seller. 48-7-128(e)(1) also contains an exemption for transactions where the seller is a partnership or S corporation or other unincorporated organization which certifies to the buyer or transferee that a composite return is being filed on behalf of the nonresident members and that the transferor remits the tax on the gain on behalf of the nonresident members. 251 (1971). Employee's Withholding Certificate. Filed by: Filed on: April 12, 2013, Last updated: April 12, 2013, Filing Status (e.g. On the other hand, the right to file a consolidated return is subject to consent by the Commissioner. Such inventory is then subject to normal rules (i.e. Filing Separately, Head of Household) Number of Leaders Attach a photocopy of this form to the form which has received the certification letter. Under this scenario, the nonresident partner often found himself in the following unhappy position: The Revenue Department has similarly been frustrated by the practical inability of reaching nonresident partners and shareholders of S corporations, especially in those cases where the tax liability is modest and collection impractical.C. The regulations adopted under this section appear at Reg. Reg. Filing Separately, Head of Household) Number of Members Attach a photocopy of this form to the form which has received the certification letter. A decision is expected at any time. 560-7-8.34(6) contains an extremely important anti avoidance clause. This from is to be completed by a nonresident member to certify exemptions from the O.C.G.A 48-7-129 nonresident withholding requirements. D. Definition of Residents and Nonresidents. The Revenue Department has informally indicated this may be correct and is studying the issue. One of the most interesting aspects of O.C.G.A. (3)Calculation of tax. According to the report contained in the pleadings, this resulted in 90% decrease in Georgia taxable income. Similarly, such partners generally did not file any returns in Georgia. 550, 62 USLW 3374). 48-1-8(a) for the first time as follows: Finally, amendments to O.C.G.A. An official website of the State of Georgia. Practical Problems. However, if the amount required to be withheld exceeds the net proceeds payable, the withholding is limited to the net proceeds actually payable. Equitable Apportionment.Bechtel Power Corporation v. Collins, Fulton Superior Court No. D. Problems of Interpretation of the Statute and Regulatory Response. Taxation of Computer Software for Ad Valorem Tax Purposes.A. G-7NRW Nonresident Withholding Return Thus, the statute represents an extremely important exception to the general rule of non-liability of shareholders and limited partners. 560-7-8-.34, Georgia Department of Revenue, effective August 13, 2012 Each member is required to sign the attached form. The auditor disallowed the royalty deduction and assessed tax on Aaron Rents for additional taxes as if no royalty payment had been made. If you're not yet registered with the GTC, simply follow the instructions GTC provides to create an account. This list is also provided with the form aspage three. The Revenue Department's current position is that "canned" or "prewritten" software is taxable for sales tax purposes, but that "custom" software is not. The Q&A indicate the common sense net proceeds means amounts paid to Seller. 560-7-8-.34(1)(a) makes reasonably clear that a distribution means an actual distribution to a member or a segregation of funds for the benefit of the member. Form used to apply for a refund of the amount of tax withheld on the 2021sale or transfer of Maryland real property interests by a nonresident individual or nonresident entity which is in excess of the transferor/seller's tax liability for . By virtue of Reg. Div. The Q&A's affirm that only taxable transactions are subject (Q&A - 9). 48-7-128 test, as this appears to be the intent. 2% Non Resident Contractor Phone: 1-844-898-8542 Email: WithholdTax@dor.sc.gov Summary: Code 12-8-550 requires persons hiring or contracting with a nonresident taxpayer to withhold 2% of each payment made to the nonresident under the contract that exceeds $10,000. Form NRW-Exemption (REV 7/13) 2 4. The regulations adopted under this section appear at Reg. This includes Agents and Agencies for new submissions. Due to the passage of the Illegal Immigration Reform and Enforcement Act of 2011, the Georgia Department of Insurance is required to verify the lawful presence of all new applicants subject to licensure by the Department of Insurance. Nonresidents who sell or transfer Georgia real property are subject to a 3% withholding tax. State of Georgia government websites and email systems use georgia.gov or ga.gov at the end of the address. If the seller transferor is a corporation or limited partnership it is registered to do business in Georgia. Filing Status (e.g. A petition for certiorari to the Supreme Court was denied on November 29, 1993 (114 S.Ct. Much of the "law" is little more than instructions to various tax forms and unwritten Revenue Department policies. However, the Revenue Department also had indicated that the county administrative offices were free to examine the issue and would not preclude their efforts to assess taxpayers.Some commentators had urged that the line could be drawn between software inventoried physically in diskettes for sale, which would be subject to taxation based upon the rules applicable to inventory, versus the intangible residual inherent in the software as intellectual property. The Revenue Department had indicated, at least informally, that custom computer software should constitute intangibles and not be subject to the ad valorem regime. The schedule must include the name, address, social security number, and any amount distributed to any nonresident member not included in the composite return. We will resume normal business hours Tuesday, January 17. 48-6-21(9), even as it existed prior to the 1993 amendment described below, intangible personal property included a category of property including "patents, copyrights, franchises, and all other classes and kinds of intangible personal property not otherwise enumerated." 48-1-8(a) for the first time as follows: Finally, amendments to O.C.G.A. 48-7-129. If the seller provides an affidavit of gain, place that amount on line 1. However, the list of items which do not justify undue hardship is so exhaustive that it will be a rare case indeed where the withholding obligation will be excused. If you are a motorist driving in Georgia, the chances are that you are sharing the road with many drivers who are not Georgia residents. Complete Form W-4 so that your employer can withhold the correct federal income tax from your pay. Specifically, pursuant to O.C.G.A. D096025 and Merck v. Collins, Fulton County Superior Court E-3677. (a)Withholding requirement and tax rate. The due date of the return is the same as for a calendar year individual. This section raises interesting implications about the taxability for Georgia Sales and Use Tax of other "non inventory" software.IV. According to the report contained in the pleadings, this resulted in 90% decrease in Georgia taxable income. First, computer software is defined in O.C.G.A. FRANKFORT, Ky. (July 15, 2019) Due to recent legislative changes, the Department of Revenue (DOR) has updated the Resale Certificate (Form 51A105) to include the services that are now exempt for resale, effective July 1, 2019. Payment should be remitted with required Form G-7-NRW. (1973).B. Managing Enterprise Data in a Federated Development - AFITC, Integrate Electronic Signature 911 Release Form PDF, Integrate Electronic Signature Coronavirus Press Release, Integrate Electronic Signature Personnel Daily Report, Integrate Electronic Signature Basic Scholarship Application, Integrate Electronic Signature Scholarship Application Template, NRW-Exemption - Department of Revenue - Georgia.gov. hbbd```b``^".0 "#H`q\'0,m ?LHE ej`X$ .md6 XVg69H)/#U p! Each member is required to sign the attached form. The case was tried before Judge Long this spring and final post trial briefs submitted. Similarly, a trust administered outside of Georgia is a nonresident, presumably irrespective of the state of creation. 48-7-128(d) that solve some of the most chronic problems. If you have any media inquiries or would like additional information, please click here. How you can complete the Instructions for South Carolina sellers affidavit nonresident seller withholding code section 12 8 580i 295 form 2001 online: To get started on the document, utilize the Fill camp; Sign Online button or tick the preview image of the form. For some years the State of Georgia has had audit teams specifically assigned to the audit and assessment of Georgia income tax against nonresident partners and S corporation shareholders. In response to this invitation, a committee, which has been designated as the Joint Liaison Committee jointly sponsored by the Atlanta and State Bar Tax Sections has been formed. General Rules Nonresident withholding applies if all of the following are true: You are responsible for making payments of non-wage income from Pennsylvania sources (commercial leases, royalties, services rendered, etc.). Reg. Nonresidents who sell or transfer Georgia real property are subject to a 3% withholding tax. 560-7-8-.34(3) is extremely important in that it is the first explicit regulatory guidance on the composite return methodology. Fill & Sign Online, Print, Email, Fax, or Download, Form Popularity georgia nonresident withholding exemption form. Transfers by an agency or authority of the United States of America, the State of Georgia, the Federal National Mortgage Association, the Federal Home Loan Mortgage Corporation or the Government National Mortgage Association, or a private mortgage insurance company. 48-7-128 and Ga. Comp. This required affidavit along with a copy of the secure and verifiable identificationfrom the Cf. An official website of the State of Georgia. 84 0 obj <>/Encrypt 46 0 R/Filter/FlateDecode/ID[<3B05DF6BFD548C479623F35ABAF14A62>]/Index[45 85]/Info 44 0 R/Length 125/Prev 102420/Root 47 0 R/Size 130/Type/XRef/W[1 3 1]>>stream The current guidelines establish a ceiling on fees linked with the complaint procedure. The transferor is permitted to avoid the withholding obligation upon receipt of an affidavit signed under oath swearing or affirming that the seller or transferor meets the following tests: In all other cases there is a 3% withholding obligation as to the purchase price paid. In all other cases there is a 3% withholding obligation as to the purchase price paid. The auditor disallowed the royalty deduction and assessed tax on Aaron Rents for additional taxes as if no royalty payment had been made.In Geoffrey, Inc. v. South Carolina Tax Commissioner, 437 S.E. Use of Passive Investment Companies.Aaron Rents, Inc. v. Collins, Fulton County Superior Court, Case No. The taxpayer owes tax, nondeductible interest and penalty (usually waived if reported to another state or otherwise innocently omitted). Legal Background of Uncertainty to the Statute. The statute is replete with a variety of inherent ambiguities. What is "custom" as opposed to "canned" was and is less than clear. D096025 and Merck v. Collins, Fulton County Superior Court E-3677.Delaware permits companies which limit their instate activity to receipt of a passive investment income ("Passive Investment Companies" or "PICs") to pay no income tax on the earnings from these activities. Local, state, and federal government websites often end in .gov. Nonresident Shareholder or Partner Affidavit and Agreement Income Tax Withholding Form I-309 1350 STATE OF SOUTH CAROLINA I-309 DEPARTMENT OF REVENUE NONRESIDENT SHAREHOLDER OR PARTNER AFFIDAVIT AND AGREEMENT INCOME TAX WITHHOLDING dor.sc.gov (Rev. Reg. The recent draft Q&A's take this position (Q&A - 11).F. Steps For Creating A Grant Calendar.They share with you exactly who they want it to be submitted to. Attached are copies of the statute and the regulations, as well as forms developed by the Revenue Department for implementation of the new statute.II. 48-7-129 (2010) LexisNexis Practice Insights 1. By no means do they resolve all of the issues. Before sharing sensitive or personal information, make sure youre on an official state website. As you know, the three factor method of sales, payroll and property is generally applicable to businesses selling tangible personal property. If the entity is an S corporation for federal tax purposes, but the election is not effective for Georgia tax purposes. 48-7-31 provides for the methods of apportioning income as to companies doing business both within the state and outside of Georgia. 560-7-8-.34 (c) has now codified the previously unclear rule that a nonresident corporate limited partner with no other contacts in Georgia is not subject to tax withholding on its distributions. In response to this invitation, a committee, which has been designated as the Joint Liaison Committee jointly sponsored by the Atlanta and State Bar Tax Sections has been formed. If withholding is not required on a nonresident The taxpayer may have any claim for refund or credit in his home state barred by the applicable statute of limitations. The regulations make substantial progress in this regard. The Q&A's adopt this approach (Q&A - 7).H. OMB No. 48-1-8(c) is the "inventory" exception to this rule. On the other hand, the right to file a consolidated return is subject to consent by the Commissioner. (I) Nonresidents of Georgia. Except as otherwise provided in subsection (c) of this Code section, for the purposes of Chapters 5 and 6 of this title, computer software shall constitute personal property only to the extent of the value of the unmounted or uninstalled medium on or in which it is stored or transmitted. Nonresidents who sell or transfer Georgia real property are subject to a 3% withholding tax. The Revenue Department's current position is that "canned" or "prewritten" software is taxable for sales tax purposes, but that "custom" software is not. For instance they make clear that joint tenants are to be tested separately. These are to be remitted on Form G-6. %%EOF 560-7-8-.34(2)(a)(3). The Q&A's affirm that only taxable transactions are subject (Q&A - 9).C. At the same time as the legislature was enacting the partnership and S corporation withholding rules, the legislature also enacted a new withholding tax with respect to transfers of real property by nonresidents. Reg. E. Forms. A number of tax planners have actively marketed the establishment of Delaware PICs and the transfer of intangible assets to such holding companies in consideration for future payments of licenses or royalties. Georgia Nonresident Withholding Affidavit for all scenarios Execution forms acceptable for recording in GA Form GA Deed to Secure Debt cancellation Form GA Fifa cancellation South Carolina Forms Affidavit of Consideration and transfer tax exemptions I290 I295 Transferor Affidavit C268 Execution acceptable for recording in SC There was no Georgia case law or interpretation with respect to whether the concept of intangible property should include software. Your license application cannot be processeduntil the completed and notarized affidavit along with a copyof the required identificationis submitted correctly. These services are found in KRS 139.200 (g) - (q) and include landscaping services . Fill & Sign Online, Print, Email, Fax, or Download Get Form Form Popularity georgia nonresident withholding exemption form Get Form eSign Fax Email Exceptions From Withholding. Facebook page for Georgia Department of Revenue, Twitter page for Georgia Department of Revenue, tsd_nonresident_withholding_quarterly_return_g7nrw.pdf. The information presented at this site should be construed as general information only and is intended to neither offer formal legal advice nor create an attorney-client relationship. CR-AFF (3/10) AFFIDAVIT BY NONRESIDENT This form is to be completed by a nonresident member included in a composite return filing whose tax is computed under Options 1 or 2 of Regulation 560-7-8-.34. Appointments from the Bar are made by the Chairs of the State Bar and Atlanta Bar Tax Sections respectively. Sale or transfer of principal residences. Section 48-7-128, the following persons are Nonresidents of Georgia and are therefore subject to the withholding tax . See Beaudrot, "Current Issues in State Taxation of Computer Software -- The Georgia Experience," The Atlanta Lawyer, Volume 40, No. It should only take a moment's reflection to see that the exemption of O.C.G.A. Apparently, the taxpayer in this case has taken the position that as long as the state does not write regulations, it can adopt any method which "equitably apportions" and, thus, that the gross receipts method is appropriate and permitted. If the property qualifies as a principal residence under the Internal Revenue Code, the exemption from withholding applies for the gain that is excluded from Federal AGI under the Internal Revenue Code. Appendix. The filing of estimated tax payments by the member does not relieve the entity from the responsibility of the withholding requirement. 48-7-27(b)(6) are considerably narrower than the federal test in that the replacement property must be located in Georgia. The AT&T case raises the issue of whether the Commissioner abuses his discretion by refusing to permit a taxpayer to file on a consolidated basis if it is a unitary operation and if this will result in more accurate representation of business level activity and, incidentally this will also reduce Georgia tax.The case was tried before Judge Langham in September and briefed before Thanksgiving. 3.I am the seller of the property described in the attached description. Nonresident Beneficiary -- Affidavit and Agreement Income Tax Withholding Form I-41 Reset Form 1350 dor.sc.gov STATE OF SOUTH CAROLINA DEPARTMENT OF REVENUE NONRESIDENT BENEFICIARY AFFIDAVIT AND AGREEMENT INCOME TAX WITHHOLDING Print Form I-41 (Rev. If the entity is a partnership, the partnership is a publicly traded partnership. Primary Forum for posting questions regarding tax issues. implicitly subject to ad valorem and sales tax). In this regard, the industry was most fortunate to enlist the support of Governor Miller. Perhaps the most frequent pattern is that of the nonresident individual partner who has an interest in a syndicated Georgia partnership or entity. 48-6-21 classify computer software, as so defined, as an intangible, thus removing it from the domain of the county tax assessors.The net result is that software is valued only to the extent of the medium and is taxed as an intangible. Filing Separately, Head of Household) Number of Members Attach a photocopy of this form to the form which has received the certification letter. Alternatively, O.C.G.A. Withholding on Distributions to Nonresident Members of Partnerships, Subchapter S Corporations and Limited Liability Companies.A. Georgia's Nonresident Withholding Requirement Under Georgia law, a passthrough entity that conducts business in Georgia must withhold and Tiered Situation Exemption pursuant to Regulation 560-7-8-.34 . Georgia Withholding Tax The sale of real estate by a non-resident of Georgia may trigger a withholding tax based on either the sales price or the amount of the Seller's gain. If the seller is an entity which files a composite return and remits the tax on the gain on behalf of its members, then the buyer is not required to withhold. If the purchase price exceeds $20,000, the tax liability is less than $600, and the seller signs an affidavit certifying the gain, the buyer will not be required to withhold. The current membership of the Joint Liaison Committee from the private sector is: Charles R. Beaudrot, Jr., Bobby L. Burgner, Albert Caproni, Raymond P. Carpenter (Co-Chairman, State Bar), N. J. Citron, John L. Coalson (Co-Chairman, Atlanta Bar), Frank DeLuca, Peter Fishman, CPA, Stephen E. Forbes, Tim Gillis, Gary Hickman, Joann Jones, Patrick G. Jones, Richard M. Morgan, Linda W. Munden, James L. Underwood, CPA, Michael L. Wood, CPA.The formation of the Joint Liaison Committee represents an intelligent and laudable effort on the part of the Revenue Department to solicit comments and assistance with respect to proposed regulations and issues of concern to businesses and their tax advisors in Georgia.I. If withholding is not required on a nonresident employee's wages, you must file Form HW-7, Exemption From Withholding on Nonresident Employee's Wages, and the original Form HW-6 with the Department. The court concluded that the licensing of the trademarks alone created nexus in South Carolina. Georgia nonresident withholding requirements - The Litwin Law . Basic Structure. How you know. (A copy of the amended form is included with these materials). Before sharing sensitive or personal information, make sure youre on an official state website. If you are a nonresident alien at the end of the tax year, and your spouse is a resident alien, your spouse can choose to treat you as a U.S. resident alien for tax purposes and file Form 1040 using the filing status "Married Filing Jointly." Remote work arrangements during the COVID-19 pandemic revealed the problems with the hodgepodge of state rules. Also, the term as defined makes clear it does not apply to payments made to a member in a capacity other than as a member (e.g., as salary, rents or royalties). withhold three percent (3%) of the realized gain (that amount is subtracted from the seller's proceeds). The salient concepts of this withholding statute are the following: It imposes a 4% withholding on the entity as to distributions "paid or credited" to the nonresident. 48-7-128(c) specifically permits that by providing an appropriate affidavit computing the actual amount of gain withholding can be calculated at 3% of such amount. is to be provided with your application. Whether such software was taxable as "tangible personal property" for ad valorem tax purposes was highly debatable. Local, state, and federal government websites often end in .gov. Payment of Withheld Taxes. Section 40-18-86, Code of Alabama 1975, provides for income tax withholding at a rate of 3% or 4% on sales or transfers of real property and associated tangible personal property by nonresidents of Alabama.This Code Section is applicable to any sale or transfer occurring on or after August 1, 2008. 560-7-8-.34(2)(b) is extremely important in that it formalizes that for partnerships and S corporations with income from both within and without the State of Georgia, that such income must be apportioned and allocated based upon O.C.G.A. Withholding Tax on Sale or Transfer of Real Property and Associated Tangible Personal Property by Nonresidents. Registration. Message Board participants can then respond to your questions. 560-7-8-.34(c) has now codified the previously unclear rule that a nonresident corporate limited partner with no other contacts in Georgia is not subject to tax withholding on its distributions. In the Aaron Rents case, Aaron Rents paid its PIC 2% of its gross sales as a royalty on the "Aaron Rents" trade name. 1017, Resident and Nonresident Withholding . 350. State of Georgia government websites and email systems use georgia.gov or ga.gov at the end of the address. Although there is some uncertainty within the Revenue Department as to how this should be interpreted, it seems reasonably clear that the Revenue Department contends that withholding applies in the situation where funds are separately accounted for or set aside for a partner, something analogous to a "constructive receipt" test. What is "custom" as opposed to "canned" was and is less than clear.More generally, there was a fundamental question as to why software would not be properly categorized as an intangible. As a policy matter, but with no regulatory sanction, the Revenue Department generally insists that service companies use a three factor formula and be done with it. Frequently, the nonresident partner would report any income from the Georgia partnership on the tax return of the state of his domicile assuming, erroneously, that such income is analogous to dividend income from stocks, the income of which is generally taxable in the state of domicile of the holder of the interest. 48-6-21 classify computer software, as so defined, as an intangible, thus removing it from the domain of the county tax assessors. Withhold on distributions to nonresident beneficiaries. The AT&T case raises the issue of whether the Commissioner abuses his discretion by refusing to permit a taxpayer to file on a consolidated basis if it is a unitary operation and if this will result in more accurate representation of business level activity and, incidentally this will also reduce Georgia tax. INTRODUCTIONIn the summer of 1993, Jerry Jackson, Deputy Commissioner, contacted the Taxation Section of the State Bar and the Atlanta Bar Tax Section requesting the Bars' participation in the formation of a new committee to solicit comment from tax professionals with respect to issues of importance. There is much lore and little law. If you did not receive an affidavit of gain from the seller, then you must first calculate the amount realized from the sale by subtracting the selling expenses from the selling price to determine . The Legislative Response. Specifically, pursuant to O.C.G.A. They specifically state that not only can the officially sanctioned forms be used, but any closing statement, transfer statement or other documents containing all of the requisite information can be used. 48-1-8(c) is the "inventory" exception to this rule. A pass-through entity is any business that is recognized as a separate entity for federal income tax purposes and the owners of which . Apportionment and Allocation. See SC Revenue Ruling #09-13, available at dor.sc.gov/policy, for information about this affidavit. Fiscal Years. An official website of the State of Georgia. Keep a copy of your employee's Form HW-6 for your records. v. Collins, Fulton County Superior Court, Case No. [Videotapes are tangible personal property for sales tax purposes even though they consist of at least three different components: tangible medium, intangible contents and limited right to use the encoded program.]. Assessors in certain counties, mainly in Metro Atlanta, took the position that capitalized software constituted tangible personal property and was therefore subject to tax as personal property.Whether such software was taxable as "tangible personal property" for ad valorem tax purposes was highly debatable. Save, print, or complete templates in the online editor. Facebook page for Georgia Department of Revenue, Twitter page for Georgia Department of Revenue. Please use the Contact Us link above for customer support questions. @1I*m8u^cO:YyH9%0( 0W@ I=-V12Z;$P ]i9 [=T!CM" rY<9O(. A. A. Each leader is required to sign the attached form. A decision is expected at any time. premium income and is not subject to Georgia income tax. Recipients will be required to include copies of two of the Form G-2(A) with their Georgia income tax return. The regulations and forms are silent as to the tax treatment of like kind exchanges. Georgia Title Georgia Withholding Tax for Non Residents. 48-6-21 and represents an interesting grafting of several concepts. Forms. 7/30/19) 3346 I certify and agree to the following: 1. Nonresidents are to be given a reconciliation within thirty days of the close of the taxable year of the entity with respect to which the withholding payments were made. Also, the forms do not really address the issue. The state has consistently refused to adopt regulations which would resolve these issues. 189 (N.Y. App. That withheld amount is then sent in by the closing attorney to the Georgia Department of Revenue (in some instances the seller can get the amount withheld back from the GA DOR). 1 (1993).B. Fill out and submit any required forms. Merck is still in discovery and negotiation of the stipulation of facts.V. Aaron Rents, Inc. v. Collins, Fulton County Superior Court, Case No. Otc Form Ow-15 Is Often Used In Oklahoma Tax Forms, Oklahoma Tax Commission, United States Tax Forms, Tax, Oklahoma Legal Forms And United States Legal Forms. FORM 10-K (Annual Report) Filed 04/01/13. Assessors in certain counties, mainly in Metro Atlanta, took the position that capitalized software constituted tangible personal property and was therefore subject to tax as personal property. There is much lore and little law. Merck is still in discovery and negotiation of the stipulation of facts. A copy of the approved form is attached at the end of this section. 550, 62 USLW 3374).Aaron Rents was argued in March before Judge Eldridge who has referred the case to Roland Barnes as magistrate. The taxation of nonresident shareholders of S corporations and nonresident partners of partnerships has long been an extremely murky area. Such passive income can include interest, dividends, and license and royalty fees with respect to patents, copyrights, trademarks, trade names, service marks or other intangible assets.A number of tax planners have actively marketed the establishment of Delaware PICs and the transfer of intangible assets to such holding companies in consideration for future payments of licenses or royalties. 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