Category: Residence

No place to hide from the taxman – Seychelles signs automatic tax information sharing agreement

(Seychelles News Agency) – The Seychelles has become an early adopter of an agreement launched by the G5 group of countries – the United Kingdom, France, Germany, Italy and Spain – to automatically disclose details of individuals who have taxable income kept in offshore accounts. According to a press statement by Her Majesty’s… – Continue reading

Offshore incorporations up in Cayman and worldwide

Despite the political and media pressure on offshore financial centers, new incorporations of offshore companies worldwide continue to grow. A new report on offshore company incorporations by law and fiduciary firm Appleby shows that new company registrations increased in most offshore jurisdictions in the second half of 2013. “As the… – Continue reading

Capital gains tax on non-UK residents – good news for certain institutional investors

Summary HMRC have announced that the new capital gains tax (“CGT”) charge on non-residents disposing of UK residential property, due to come into effect in April 2015, will not extend to institutional investors and companies with diverse ownership. Background In the Autumn Statement last year, the Chancellor announced the new… – Continue reading

Expats urged to review sources of UK income amid tax raid plans

Property owners and pensioners who face losing their personal tax allowances can take steps now to protect themselves, say experts Expats facing the possibility of losing their personal allowance under a tax raid proposed by George Osborne should not panic but look carefully at where their UK sources of income… – Continue reading

Canadians File Suit To Block FATCA And Prohibit Handover Of U.S. Names To IRS

A lawsuit has been filed by several Canadian citizens against the Canadian Attorney General in Federal Court in Canada. The legal claim challenges the constitutionality of the agreement the Canadian government struck with the United States. The controversial deal between nations was inked under FATCA—the Foreign Account Tax Compliance Act…. – Continue reading

Local Law Shopping Through “Derivative Benefits” re: Tax on Foreign Income

Unlike U.S. persons who are subject to U.S. federal income tax on their worldwide income, foreign persons generally are subject to U.S. taxation on two categories of income: (i) certain types of passive U.S.-source income (e.g., interest, dividends, royalties and other types of “fixed or determinable annual or periodical income,”… – Continue reading

UK Reduces Scope Of New Property Gains Tax

The British Property Federation (BPF) and the Chartered Institute of Taxation (CIOT) have welcomed an announcement from HM Revenue and Customs (HMRC) that institutional investors and companies with diverse ownership will be excluded from plans for a new capital gains tax (CGT) on UK properties sold by non-residents. The charge… – Continue reading

Reduce Your Tax Burden Through Property Investment in Mauritius

PORT-LOUIS, Mauritius, August 6, 2014 /PRNewswire/ — Living on a paradise island has always been your dream? Don’t look any further. Mauritius is the right destination. Located in the pristine turquoise waters of the Indian Ocean, Mauritius is a small tropical island, only 12 hours of flight from Paris. Since… – Continue reading

Real estate taxes soar along with home prices

One side effect of soaring home prices: Real estate taxes are soaring too. The government provides many incentives to homeownership, including the mortgage-interest deduction and capital gains exclusion. But the interest deduction is generally limited to interest on $1.1 million in mortgage debt. And the capital gains exclusion is limited… – Continue reading

Russian FM Provides Anti-Offshore Law Update

Russia’s Finance Minister, Anton Siluanov, has told President Vladimir Putin that a new bill to deter Russian tax residents from hiding income offshore is expected to raise about RUB30bn (USD844m) from overseas accounts in Cyprus and the Netherlands. During a Government meeting on July 30, 2014, Siluanov explained that entrepreneurs… – Continue reading

TIPS FOR BEING FATCA COMPLIANT

This June the IRS modified its offshore disclosure programs to encourage U.S. citizens to come forward and report their assets and mitigate risk of penalty or prosecution. To help your clients avoid running afoul of FATCA, a bulletin from PwC advises them to: Determine citizenship. In some cases, non-resident Americans are… – Continue reading

Russian government to submit offshore taxation bill to parliament

Therefore, Russia “could receive about 30 billion rubles [about $900 million] in additional budget revenues [annually], which are extremely necessary,” Finance Minister Anton Siluanov noted NOVO-OGARYOVO, July 30. /ITAR-TASS/. Russia’s new offshore taxation rules will yield about $1 billion in tax revenues for state coffers annually, Finance Minister Anton Siluanov… – Continue reading

India: Permanent Establishment Is A Separate Entity For The Purpose Of Transfer Pricing – ITAT Hyd

The Income Tax Appellate Tribunal (ITAT), Hyderabad Bench has recently held in the case of DCIT, Hyderabad vs. M/s IJM (India) Infrastructure Ltd, Hyderabad (2014-TII-114-ITAT-HYD-TP) that a permanent establishment (PE) of a foreign company has to be treated as separate entity for the purpose of transfer pricing and that any… – Continue reading

China’s new Enterprise Income Tax regulation and its impact on international transportation business

As reported in Clyde & Co’s 2011 article titled ‘Chinese charterers deducting taxes from hire payments’ (click here to view), foreign vessel owners engaged in business with Chinese charterers have long faced China’s Enterprise Income Tax regime (“EIT”). That regime looks set to extend further into the international transportation sector… – Continue reading

Don’t get taxed by a foreign stint

An overseas assignment is definitely exciting, but it pays to understand the double taxation issues that might arise Even with a lucrative compensation package, an assignment overseas could be taxing if there are unplanned outflows, particularly on account of double taxation. Here’s a couple of commonplace situations you might find… – Continue reading

FBR wants powers to access bank accounts, seek private information

ISLAMABAD: The FBR is seeking extraordinary powers to access private bank accounts of citizens, apparently to catch tax dodgers, locate assets beyond means, sources of funds, detect foreign travels and raise revenue for the government. For the purpose, the FBR has recommended that its intelligence wing be allowed to perform… – Continue reading

Aussie tax residence different

OPINION: In February and April I wrote about a decision of the Taxation Review Authority (TRA) that found a taxpayer was still a New Zealand tax resident despite living predominantly outside New Zealand for more than 10 years. In those articles I highlighted why I thought the authority’s decision was… – Continue reading