When Canada’s banks reopen for business on July 2, they will begin formally operating as informants for the United States Internal Revenue Service — the IRS. Financial institutions in Canada will be required to ask all new and existing clients opening a new account questions such as where they were… – Continue reading
Are you an American resident? It’s a question that Canadian “snowbirds” will have to ask themselves before celebrating Canada Day next week, when the U.S. Foreign Tax Compliance Act – or FATCA – kicks into effect. Financial institutions around the world will answer to the U.S. Internal Revenue Agency so… – Continue reading
An oldie-but-goodie tax strategy is back in the limelight thanks to the Clintons’ much-publicized attempts to soften the blow of estate and gift taxes. The qualified personal residence trust is back. Bill and Hillary Clinton are making headlines for their use of the qualified personal residence trust or QPRT —… – Continue reading
Are you an American resident? It’s a question that Canadian “snowbirds” will have to ask themselves before celebrating Canada Day next week, when the U.S. Foreign Tax Compliance Act – or FATCA – kicks into effect. Financial institutions around the world will answer to the U.S. Internal Revenue Agency so… – Continue reading
Q. I have lived in my house for 30-plus years. I have been told that if I sell it for more than I paid for it, I will have to pay capital gains tax on the difference between what I paid for it and what I sell it for. Others… – Continue reading
ANYONE with a second residence or holiday home in Co Donegal who has not paid the taxes due on it now have an outstanding bill of €4,220. This amount, accrued from 2009-2013, will rise however to a whopping €7,230 on September 1, 2014. Donegal County Council said it is “actively… – Continue reading
This year, Park City primary residence owners will have to pay $18 more per $500,000 of assessed valuation in property taxes. That is because the Park City School District has imposed a one-time judgment levy to make up for the $760,000 it will have to refund to taxpayers after the… – Continue reading
With regard to business operations, a resident of one country (e.g., Panamanian company) may be taxed in the other country (e.g., Israel) if it has a “permanent establishment” (PE) in the other country. Panama is famous for its canal, colorful history and cool offshore tax regime. To that we can… – Continue reading
As the Justice Department winds down its eight-year crusade against Swiss banks selling offshore tax-dodging services to wealthy Americans, the Internal Revenue Service is offering its own parting gift: softer penalties for taxpayers who come out of the woodwork to disclose their secret accounts. Call it the advent of the… – Continue reading
US multinationals incorporated in Ireland should have their entire global operations taxed here, a leading academic has claimed. Addressing the Oireachtas sub-committee on global taxation yesterday, Jim Stewart, associate professor in finance at Trinity College Dublin, said that existing tax residency rules, for multinational firms, are “extremely ambiguous” and suggested… – Continue reading
The organisations making the payments are required to withhold tax from such payments and pay over the withheld amounts to their respective relevant Tax Authorities within 30days of receipt of payment or credit by the person or entity suffering the Tax. The relevant tax authorities to receive the WHT tax… – Continue reading
Medtronic Inc. (MDT), the globe-spanning medical device maker founded in a Minneapolis garage in 1949, is poised to become the biggest company yet to escape the U.S. tax system by shifting its incorporation abroad. Medtronic said yesterday it plans to take a legal address in tax-friendly Ireland as part of… – Continue reading
Tens of thousands of Irish people and foreign nationals who have worked and lived in the UK or US and still have investments, property or pension funds there, are particularly vulnerable to those countries’ tax regulations. Soon, one group in particular – the nearly 12,000 American citizens living in Ireland… – Continue reading
Tax season is over for Canadians, but Americans living in Canada – even those with Canadian citizenship – still face complex filing obligations imposed by U.S. authorities. And it could be a punishing weekend for anyone who has not begun preparing for Monday’s deadline. “Americans living in Canada are required… – Continue reading
One of America’s best-known stores may soon decide that it’s no longer American. If it does, you will pay the price and feel real sick about it. Walgreens pharmacy is in every way an American company. It was founded in Chicago in 1901 and maintains its headquarters in Illinois. It… – Continue reading
Apple Operations International, the principal Irish holding company for foreign subsidiaries, was not always stateless for tax purposes based on the last filed accounts in Ireland. It stopped paying tax in Ireland from 2006, based on US Senate Permanent Subcommittee on Investigations evidence. The most explosive revelation in the May… – Continue reading
New agreement The new double tax agreement between Cyprus and the United Arab Emirates took effect from January 1 2014. For the most part, the agreement reproduces the corresponding provisions of the latest Organisation for Economic Cooperation and Development (OECD) Model Tax Convention verbatim. The principal departures from the OECD… – Continue reading
The US tax authorities are set to make the amnesty programme aimed at encouraging US citizens to declare any offshore bank accounts less tough. Recently appointed head of the US Internal Revenue Service (IRS), John Koskinen, said at a tax conference in Washington D.C. that re-striking the balance between enforcement… – Continue reading
Thousands of investors worldwide are finding out that controversial new US tax avoidance laws have a much wider reach than just American taxpayers with offshore accounts. This is because an unforeseen consequence of the new Foreign Account Tax Compliance Act (FATCA) is international customers of US financial institutions must reveal… – Continue reading
The United States government has actively been pursuing NRIs who have undisclosed offshore assets and income. The United States law requires citizens and residents (i.e., green card holders, H1-B visa holders, and other tax residents) to report their worldwide income and complete a Report of Foreign Bank and Financial Accounts… – Continue reading
At present, it is unclear how the rules surrounding Private Residence relief (PPR) will exempt individuals from these new CGT rules. In his 2013 Autumn Statement, Chancellor George Osborne announced an important change to the UK tax system – namely, the extension of capital gains tax (CGT) to non-residents selling their… – Continue reading
European Union member states should adopt a common position on corporation tax in the current debate on changing global tax rules, according to a high level European Commission report on the digital economy. The report says that the OECD’s Base Erosion and Profit Shifting project (Beps), which is examining how… – Continue reading
Nearly 6 million Americans living abroad are facing a June 16 deadline to file their taxes this year. Regardless of the confusion that U.S. citizens abroad have over what will ultimately be required of them under the Affordable Care Act and other laws, all taxpayers whose income exceeds $10,000 are… – Continue reading
The best way to deal with B.C.’s socially and economically harmful Property Transfer Tax would be to scrap it. However, the B.C. Chamber of Commerce is promoting a second-best solution that has a far better chance of winning support from provincial politicians hooked on spending our money. The Chamber’s approach,… – Continue reading
CALGARY – A Calgary-based United States tax expert has recommended to the federal government that Canada follow the lead of other countries and include certain Canadian trusts within the definition of organizations subject to reporting under the recent Intergovernmental Agreement between the Canada and the U.S. “This would eliminate the… – Continue reading
When it comes to being an expat, as far as the UK taxman is concerned, absence does not make the heart grow fonder. A tax specialist gives tips on avoiding problems. There is no avoiding the fact that moving overseas or returning to the UK creates some tax issues, and… – Continue reading
Increasing numbers of the wealthy global elite are saying goodbye to their home country and taking up residence elsewhere in an effort to preserve their riches. Popular destination countries like Cyprus, Spain and Australia have programs that offer a path to citizenship or permanent residency — for those who can… – Continue reading
Moving abroad to start a new job can be one of the most exciting yet stressful experiences of your life — but it can also end up saving you a bundle in federal income tax. This is because U.S. expatriates frequently take advantage of the foreign earned income exclusion to… – Continue reading
Following the recent offer by U.S drugmaker Pfizer to acquire British pharmaceutical firm AstraZeneca, congressional Democrats are proposing new limits on the ability of U.S.-based firms to establish foreign residence and thus cut their U.S. corporate tax bill. Even before this latest flap, the Obama Administration proposed curbs on this… – Continue reading
Uncle Sam is poised to poke his pointy nose into the financial affairs of millions of Canadians who have no connection to his country, and – no matter how distasteful you find this – pushing back will only make it worse. This is the gloomy – but credible – conclusion… – Continue reading
NASSAU, Bahamas — The government has been urged to implement an investor-citizenship program that would effectively allow high-net-worth individuals (HNWIs) to trade investment in The Bahamas for citizenship rights as a means of spurring growth in the economy. Sean McWeeney QC, a partner with law firm Graham Thompson and Co., is advocating… – Continue reading
The Chartered Institute of Taxation (CIOT) has voiced concern over the proposed withdrawal of the principal residence election for all taxpayers. The authority has responded to HM Revenue and Customs’ (HMRC) plans to extend capital gains tax (CGT) to non-residents in certain circumstances, and fears the proposal could have a significant… – Continue reading
More than three quarters of American expats and green card holders who have taken out a supplementary overseas pension contract are able to mitigate the effects of the Foreign Account Tax Compliance Act, it is claimed. The FATCA created controversy when it was announced, as it appeared that people would… – Continue reading
Residential property owners need to be aware of some proposed changes, which will have a significant impact on their CGT liabilities. Final period exemption reduced If a property has, at any point, qualified as an individual’s main residence then the final 36 months would have been covered by relief from… – Continue reading
Corporate Tax Avoidance: Last week the news that Apple is considering buying Beats Electronics, a maker of expensive headphones that was founded by record mogul Jimmy Iovine and rap artist Dr Dre, for $3.2bn, got a lot of media attention. Dr Dre must have pissed-off Apple when he bragged on… – Continue reading
Puerto Rico’s tax incentive acts are tailor-made for traders, investors, investment managers and financial institutions. Enacted in 2012, Puerto Rico’s Act 22 allows investors and traders with bona fide residence in Puerto Rico to exclude 100% of all short-term and long-term capital gains from the sale of personal property accrued… – Continue reading
BASSETERRE, St. Kitts – NEWS reaching this publication states that a businessman from Wyoming, United States of America was on Wednesday (May 7) sentenced to serve 36 months in jail for tax evasion. According to a US Department of Justice press release, the businessman, Robert C. Sathre, appeared before US District… – Continue reading
Introduction Article 10 of the Russia-Cyprus double tax agreement grants taxing rights over dividends to the state of residence of the company paying the dividends (in addition to the state of residence of the recipient). The tax that may be imposed in the state in which the dividends originate is… – Continue reading
The OECD has been prolific in its publication of discussion documents since the start of the year. OECD discussion draft documents have been released in respect of: Action 13: Transfer pricing documentation and country by country reporting – 30 January 2014 The BEPS Action Plan issued on 19 July 2013… – Continue reading
Given the proximity of Canada to the U.S., it is not surprising that many Canadians own real estate south of the border. Some, especially those who are retired snowbirds, also spend a good part of the year in the U.S. It is important to understand what the tax implications are… – Continue reading
Canadians who spend their winters in the warmer climates of the United States may be attracting some unwanted attention starting this year. A new tax treaty between Canada and the United States has spawned a cozy relationship between the Canada Revenue Agency and the U.S. Internal Revenue Service. The two… – Continue reading
LONDON — They are the most expensive and luxurious flats in the whole of London. Their ultramodern bay windows offer an unobstructed view onto Hyde Park. An underground corridor connects them to the Mandarin Oriental, the palace where Michelin-starred chef Heston Blumenthal has one of his prized restaurants. In total, the… – Continue reading
The European Union has formally adopted the Savings Tax Directive after six years of negotiations. The directive is intended to bolster the power of the EU to crackdown on tax evasion. The measure was adopted shortly after Luxembourg and Austria abandoned their opposition to the plan. EU tax commissioner Algirdas Semeta, commenting… – Continue reading
The European Council has adopted a directive over exchanging information on savings incomes in a bid to clamp down on tax fraud and evasion The directive will strengthen EU rules over the exchange of information on savings incomes and help member states to share details and information more easily. Directive 2003/48/EC… – Continue reading
Look before you leap out of Israeli residence. Israel now has tax rates below the OECD average and no estate or inheritance tax. Israeli residents relocate abroad for a variety of reasons, sometimes business, sometimes personal. If the relocation is for a short period, they will typically claim various expense… – Continue reading
The mainland’s efforts to fight tax evasion brought in 46.9 billion yuan (HK$59.2 billion) of additional taxes in 2013, 38 times more than 2008, according to the website of the State Administration of Taxation. Since 2011, China’s transfer pricing agreements with Hong Kong and Macau have saved 34.57 billion yuan… – Continue reading
High quality global journalism requires investment. Please share this article with others using the link below, do not cut & paste the article. See our Ts&Cs and Copyright Policy for more detail. Email ftsales.support@ft.com to buy additional rights. The British Virgin Islands, Liechtenstein and Jersey are among 44 countries that have set… – Continue reading
Not a single company has contacted the tax authorities to say they have been affected by changes announced in the budget as part of Finance Minister Michael Noonan’s clampdown on international tax avoidance. In October’s budget, Mr Noonan included a measure that required any company incorporated in Ireland to be… – Continue reading
Inland Revenue today released its interpretation of what it means to be tax resident. “This is a particularly important document for New Zealanders living and working overseas. For these people, remaining tax resident in New Zealand can have significant financial implications.” says Rebecca Armour, Tax Director and Head of International… – Continue reading
As of January 1st 2014, Cyprus entered into five new Double Tax Treaties (DTT’s) with Estonia, Finland, Portugal, Spain and Ukraine expanding its already rich list of DTTs. All the agreements aim to avoid double taxation between the mentioned countries and follow the OECD conventional model on income and capital. The… – Continue reading
