Category: Residence

Your Taxes: Israel to sign tax treaty with Panama

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

IRS Will Now Accept an ‘I Was Clueless’ Defense for Offshore Tax Evaders

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

Tax all profit of firms incorporated here’

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

Administration of withholding tax (2)

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

Tax date looms for Americans in Canada

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

Apple’s principal Irish company became stateless for tax purposes from 2006

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

Cyprus: New Cyprus-UAE Double Tax Agreement Takes Effect

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

Offshore Voluntary Disclosure Program to aid NRIs with undisclosed assets

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

Canada-U.S. tax agreement raises some concerns

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

Tax Benefits of Moving Abroad for a Job

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

Tax Chauvinism: Who Cares Where a Firm is Incorporated?

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

Bahamas Urged to Push Ahead Citizenship of High-Net-Worth Investors

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

Corporate Tax: Apple, Google, Dr Dre & Ireland’s continuing stateless companies

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 Pours On Tax Incentives For Investors

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

Wyoming businessman jailed for using concealed Nevis bank account for tax evasion

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

What qualifies as direct investment under Cyprus-Russia double tax agreement?

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

Why ‘Londongrad’ Weighs On Britain’s Russia Policy

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

EU adopts landmark directive to crackdown on tax evasion

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

China’s efforts to curb tax evasion net extra HK$59b

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

Havens set deadline for reporting investors’ tax details

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 to buy additional rights. The British Virgin Islands, Liechtenstein and Jersey are among 44 countries that have set… – Continue reading

Little tax comfort for Kiwi expats

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

Cyprus: Cyprus Signs Five New Double Tax Treaties

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