To ensure that the appropriate amount of U.S. tax is paid by foreign taxpayers, whether or not such taxpayers file a U.S. tax return, the Code requires any person paying certain amounts to foreign persons to withhold the appropriate amount as an agent of that foreign person. U.S. Tax Withholding on Payments to Foreign Persons provides an insider's look into this complicated area. It focuses on the circumstances under which the relevant taxing authority maintains effective jurisdiction over the payor of the income amount but not the recipient of the income, such as when U.S. source income is paid to a foreign person.

Ruth Ann Schneider has advised on non-resident alien withholding tax reporting and compliance issues for banks, broker-dealers and foreign central security depositories, and has negotiated with foreign tax officials to design international tax arrangements for withholding tax at-source on securities.