Why Does Residency Status Matter? An Ohio resident must pay Ohio income tax on his or her worldwide income (including investment income (i.e., dividends, capital gains etc.) and pass-through income from LLCs and S corporations with operations outside of Ohio), subject to credits for taxes paid in other jurisdictions. A… – Continue reading
Doing so would get rid of ‘overlapping and duplicative disclosure requirements,’ says advocacy group for Americans abroad The IRS’ taxpayer advocate is urging the tax service to simplify rules for Americans living overseas. Currently, foreign bank accounts must be reported both to the Treasury, in a Report of Foreign Bank… – Continue reading
The OECD Mutual Agreement Procedure Statistics for 20131 (MAP Statistics), released on November 25, 2014, show a dramatic surge in the inventory of mutual agreement procedure (MAP) cases among OECD member countries. The MAP Statistics confirm that the potential for double taxation is increasing. This is reflected most starkly in… – Continue reading
CHINA Tax Free Reorganisations • With circulars 109 and 116 jointly issued in December 2014 by the Ministry of Finance and the State Administration of Taxation, the Chinese authorities have relaxed the conditions for internal reorganisations. • Circular 109 deals with internal reorganisations. Provided the pertinent requirements are met, the… – Continue reading
The European Court of Justice recently ruled that the Netherlands may restrict the 30% fixed tax-free allowance for expatriate costs to employees living more than 150 kilometres from the Dutch border. The 150-kilometre restriction does not restrict the free movement of employees within the European Union. Consequently, an employer and… – Continue reading
Foreign owners of UK property assets are being advised to seek property valuations to avoid falling foul of changes to Capital Gains Tax, writes David Westgate – Managing Director, Andrews Letting & Management CHANGES to Capital Gains Tax for UK property investors based overseas were first announced by George Osborne… – Continue reading
On March 30, 2015, the U.S. Department of Justice (DOJ) announced that it reached the first non-prosecution agreement under the Swiss bank program with BSI, S.A. (BSI). BSI, one of Switzerland’s ten largest banks, has agreed to pay $211 million in fines and cooperate in any related civil or criminal… – Continue reading
KATHMANDU, APR 16 – With the selected consultant for the Tanahu Hydropower Project demanding income tax exemption during ongoing negotiations before signing a contract, the Nepal Electricity Authority (NEA) has said that the government cannot provide the facility as the current tax law does not allow it. The NEA clarified… – Continue reading
Suppose you own 2 houses: one in a state with an income tax and another in an income-tax-free state, such as Florida or Nevada, where you spend an increasing amount of time. You’re ready to assert you primarily reside in the tax-free state. Goodbye, big tax bill? Don’t be surprised… – Continue reading
In October 2012 Portugal launched its Golden Visa Residence Programme with the aim to provide prospective Non-EU foreign investors with the opportunity to take up residency in Portugal through investment. Recently, the Portuguese Parliament promulgated a set of new rules pertaining to this particular programme. The said rules are still… – Continue reading
NEW YORK • When it comes to taxes, corporate America is getting a bit less corporate. And a bit less American. Fueled by a wave of inversions, a record 54 companies in the Standard & Poor’s 500 Index of leading U.S. firms are now at least partially exempt from the… – Continue reading
Analysts upbeat on the company’s standalone prospects The recent share price performance of Shire Plc (LON:SHP), the London-listed drugmaker left at the altar by US pharma giant AbbVie (NYSE:ABBV) last year, suggests that the company will continue to thrive on its own, a view supported by recent analyst comments on… – Continue reading
When it comes to taxes, corporate America is getting a bit less corporate. And a bit less American. Fueled by a wave of inversions, a record 54 companies in the Standard & Poor’s 500 Index of leading U.S. firms are now at least partially exempt from the corporate income tax…. – Continue reading
1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins Canada is a federal state, with legislative powers divided between the federal and provincial governments. The federal government has legislative jurisdiction over issues concerning Canada as a whole, including foreign affairs, international trade, banking, telecommunications,… – Continue reading
Labour has claimed it will reduce tax avoidance and evasion by £7.5bn a year by the middle of the next parliament. The party has also pledged to reduce pensions tax relief for higher earners, alongside similar plans by the Conservatives. Shadow Chancellor Ed Balls laid out the target this weekend… – Continue reading
Jury selection began today in federal court in New Orleans for the trial of Seven Arts Entertainment founder Peter Hoffman and two others accused of defrauding Louisiana’s film incentive program. Hoffman, his ex-wife and producer Susan Hoffman, and actor and film producer Michael Arata were indicted last year for conspiring… – Continue reading
One of the most financially damaging taxes facing wealthier British families is UK inheritance tax. Living in Malta does not automatically protect you since liability does not rest on residence but on domicile. Domicile is a complex UK common law concept. If claiming a change of domicile, the onus is… – Continue reading
All eyes will be on former Secretary of State, and now presidential candidate, Hillary Clinton as she sets out a policy agenda during the opening months of her campaign. While in recent years Clinton has not gotten into the nitty-gritty of tax policy, she does have a long voting record… – Continue reading
Revenue figures show that just 13 people paid domicile levy of €200,000 in 2013 Ireland is home to more than 3,000 individuals or couples recognised as ‘non-domiciled’ for tax purposes, new figures from the Revenue Commissioners show. So-called “non-doms” can avoid paying tax on their worldwide income in Ireland, thus… – Continue reading
Scottish Government must work closely with councils to ensure devolution of taxation powers to Scotland brings tax and welfare systems together, according to experts. The Chartered Institute of Taxation (CIOT) also warned draft legislation could have ‘unintended complexities’, leading to double taxation on foreign income and forcing more Scottish taxpayers… – Continue reading
1. Introduction On 14 January 2015, the Swiss Federal Council opened consultations on two draft laws on the international exchange of information in tax matters. One of them deals with the OECD/Council of Europe administrative assistance convention signed by Switzerland on 15 October 2013. The other consultation deals with Switzerland’s… – Continue reading
Foreign citizens who reside in Moscow and whose income is taxable in Russia (please click here to view our Alert on personal income tax rules) starting from 1 January 2015 will need (if required) to file their annual income tax returns with the tax inspectorate of their place of registration/residence,… – Continue reading
• “Budget deficit calls for combination of cuts, and contributions,” says Seaton This week Republican Representative Paul Seaton, R-Homer, introduced a bill that would impose an income tax on residents and non-residents deriving an income source from within the state of Alaska. Proposed as a diversification strategy, Seaton said that… – Continue reading
With a retired Senate law clerk on the stand, lawyers got into the question of Mike Duffy’s “primary” residency. OTTAWA—The complicated question of just where suspended senator Mike Duffy had a “primary” residence began to be probed in depth Wednesday, with much hanging on definitions, rules and senators’ understandings. Duffy’s… – Continue reading
Labour Party leader Ed Miliband’s vow to close a tax loophole sparked fresh scrutiny on wealthy residents and drew warnings the plan could threaten London as one of the world’s major financial centers. Miliband pledged on Wednesday to abolish the non-domicile status if he’s elected on May 7, allowing some… – Continue reading
Many Canadian Snowbirds who have become fed up with Canada’s long, hard winters (and there are bound to be many more this year, especially from the Eastern provinces) have purchased winter homes in Southern U.S. states. This has been an especially popular move over the past few years, with U.S…. – Continue reading
New freedoms mean you can move your pension abroad. We show you where you’ll pay the least tax It is the ultimate dream for many people – to work hard, build up a nest egg and retire abroad to a climate with year-round sunshine. Now there is an added financial… – Continue reading
To reduce the growing urban sprawl most levels of government are allowing higher density housing in the suburbs. This means people with larger residential blocks are presented with an opportunity to subdivide and increase the value of their home. However if the correct steps are not taken when subdividing a… – Continue reading
It’s been five years since the Foreign Account Tax Compliance Act (FATCA) became law and while the intentions were good – to crack down on those hiding money offshore and avoiding taxes, compliance comes at a price for individuals and corporations. “The upside of FATCA is that it is forcing… – Continue reading
The best week in American sports is upon us. The NCAA basketball championship is tonight. The Masters starts Thursday. And today is Major League Baseball’s Opening Day. More than any other sport, baseball is a game whose fans and historians cherish numbers: 61 (73*), 755 (762*), .366, 4,256, 56, 511,… – Continue reading
According to recent estimates, the number of wealthy Russians investing in the United States ballooned in 2014 as a result of political turmoil and a disintegrating ruble causing Russians to seek a safe haven for their wealth abroad. The amount of private net capital flowing out of Russia hit $120… – Continue reading
You may be forgiven for thinking that once you no longer live in the United States, that your ongoing US tax obligations may be relatively simple or even non-existent, particularly if you have never held a US Passport or lived in the US. However the definition of US citizen is… – Continue reading
Advertisement A false image depicts undocumented immigrants as criminals because they entered the United States illegally and received many government benefits. Wars in Korea, Vietnam, Afghanistan and Iraq created labor shortages. Some industrial complexes and corporate agriculture used growing numbers of undocumented laborers to whom they paid less than minimum… – Continue reading
The South African Revenue Service has revised its guide for individuals not resident in South Africa about the tax treatment of South Africa-sourced income. Its “Guide on the Taxation of Foreigners Working in South Africa 2014/15” deals mainly with employment income. Under the country’s income tax system, only amounts received… – Continue reading
As has been widely reported, the Finance Ministry has proposed a new property tax on land and building owners. However, Prime Minister Prayut Chan-o-cha has decided to delay the new tax, citing concerns about weak economic growth and the bill’s impact on the poor. Despite the prime minister’s latest decision,… – Continue reading
As Tax Day approaches, homeland Americans scurry to file their annual tax filing obligations. But for an estimated 7.6 million Americans working and living overseas, they have an obligation to not only pay taxes in their respective countries where they live; they need to pay the piper in homeland America… – Continue reading
Rory McIlroy, the world’s number one golfer has set up home in Dubai, according to a report in the Sunday Times. The Northern Irishman, who has a long association with Dubai throughout his professional career, has filed documents in Ireland that state his primary residence is now in Dubai. During… – Continue reading
Luxembourg’s Direct Tax Administration has published a circular on February 12 clarifying issues relating to residency certificates for Luxembourg funds. These are applicable to both UCITS and non-UCITS funds regulated by Luxembourg’s investment fund legislation of December 17, 2010, which transposed the UCITS IV Directive, as well as Specialised Investment… – Continue reading
Following a period of consultation, legislation is to be included in the 2015 Finance Bill which will extend capital gains to gains accruing to a non-resident person on the disposal of a UK residential property. The charge will apply from 6 April 2015 to gains arising on or after that… – Continue reading
Despite the potential benefits of the time apportioned reduction, bed and breakfasting could be a better option for international clients Most experienced advisers will have internationally mobile clients; for example, those with spouses from different jurisdictions or those who intend to move abroad. Advising such a client can have its… – Continue reading
While the U.S. has traditionally been seen as a low-tax jurisdiction for individuals, with its many exemptions and generous deductions, its rules can bite hard for U.S. expatriates. In the past, “long distance Americans” generally responded by ignoring their U.S. tax obligations, and expat filing rates were notoriously low. Now,… – Continue reading
How to ensure landowning clients do not have shortfalls and exposure to penalties Landowners in Queensland should expect increased scrutiny of their affairs for land tax purposes. It is expected the Queensland Office of State Revenue (Queensland OSR) will increase its land tax audit activity in 2015 so landholders and… – Continue reading
Attorney-at–Law and Compliance Specialist We are living in a time where the tax landscape facing the Bahamian financial services industry is changing and evolving rapidly. On November 3, 2014, the Government executed a Model 1 Intergovernmental Agreement (IGA) with the US government to implement the latter’s Foreign Account Tax Compliance… – Continue reading
Last week, we discussed the revised set of standards for Transfer Pricing (TP) documentation and a template for country-by-country reporting (CBCR) of income, earnings, taxes paid and certain measures of economic activity as contained in Action Plan 13 of the Base Erosion and Profit Shifting (BEPS) Project. The CBCR provides… – Continue reading
Owning real property on both sides of the border can create a confusing tax situation. Consider this example. Stefan and Jane are married and live in Vancouver. Jane is a Canadian citizen while Stefan holds both U.S. and Canadian citizenship. In 1994, shortly after getting married, they bought a house… – Continue reading
The Central Board of Direct Taxes (CBDT) will issue detailed guidelines to ensure that non-resident companies holding a board meeting or two in India do not get any tax demands on their global income on account of New Delhi’s new wider definition of a resident company. Sources said the new… – Continue reading
New tax charge A new regime which will charge non-UK tax resident owners of UK residential property to capital gains tax (CGT) is due to come into force on 6 April 2015. The draft legislation was published as part of Finance Bill 2015 on 10 December 2014, after an extensive… – Continue reading
The present French Tax Update will focus on (i) certain noteworthy tax courts decisions issued in the last months of 2014 and in the first months of 2015, and (ii) the so-called projet de loi Macron (Draft Macron Law) adopted by the Assemblée Nationale in February 2015 and now discussed… – Continue reading
Authorities of the Mion District Assembly in the Northern Region are unhappy about residents’ apathy towards paying their taxes. In the direction to increase the assembly’s Internal Revenue Mobilization (IGF), a Taskforce has been established to pursue the agenda. The Mion District Chief Executive, Dan Mankandan at a public sensitization… – Continue reading
Add Ndamukong Suh to the ever-growing list of professional athletes who are bidding farewell to their high-tax home state in favor of sunnier economic climates. Suh – considered one of the top-two players in free agency this season – is leaving Detroit for Miami. By doing so, the defensive tackle… – Continue reading
