Lopez Valdes clarifies that only information given by state bodies The implications of the Law Enforcement Tax Accounts Abroad (FATCA for its acronym in English) adopted by the United States in March 2010, has generated unrest globally, because that nation imposes conditionalities that violate laws local. That legislation provides, among… – Continue reading
The MoU is designed to give some insight into the process that will be adopted by the fiscal authorities of the two countries when assessing the tax residence of a ‘person’. International investors including South African businesses already use Mauritius as their base for their growth on the continent, but… – Continue reading
On June 8th 2015, the OECD released a new package of measures for the implementation of a new Country-by-Country (CbC) reporting plan developed under the OECD/G20 Action Plan on Base Erosion and Profit Shifting (BEPS) Project, aimed at improving transparency in international tax matters. The CbC reporting plan was founded… – Continue reading
On 1 July 2015, the President of Cyprus announced a number of tax reforms. The tax reforms will aim in modernising the taxation framework of Cyprus and making it more fair and more competitive, while limiting the taxation burden and offering incentives for growth. The announcement was made while Addressing… – Continue reading
Dubai — The UAE ranked top in the world along with Malta and Monaco for lighter tax burdens placed on residents on both personal and corporate levels, according to a latest report. The annual report released by Henley & Partners revealed the outcomes of the Global Residence Program Index (GRPI)… – Continue reading
OECD and G20 Action Plan on Base Erosion and Profit Shifting (BEPS) was adopted in 2013. It consists of 15 actions including transfer pricing, taxation of controlled foreign corporations (CFC), digital commerce, hybrid instruments, international information exchange, tax treaty shopping etc. In 2013, OECD working group prepared draft documents regarding… – Continue reading
Action 3 of the OECD’s Base Erosion and Profit Shifting (BEPS) agenda promised to address how countries could use controlled foreign corporation (CFC) rules to combat BEPS. Unfortunately (or fortunately, depending upon one’s vantage point), as is pretty much universally agreed, the OECD’s draft report on CFC rules (the “draft”)1… – Continue reading
The German government has announced plans to incorporate Action 13 (guidance on transfer pricing documentation and country¬by¬country (CbC) reporting) of the OECD’s BEPS project into local legislation. The wording of the new law is being drafted and may be published some time in autumn of this year. It is the… – Continue reading
The UAE ranked 15th in an index rating countries’ residency-in-return-for-investment programmes As global economic growth slackens, a number of countries are offering citizenship or residency permits in return for investment in their markets. According to the latest Global Residency Programme Index by Henley & Partners, Portugal topped the list with… – Continue reading
We consider the retirement options for three top expat destinations – New Zealand, Bahrain and Singapore Retiring overseas is an aspiration for many expats, especially after they have spent much of their working life outside the UK. But while you may think you know what’s involved, there are many things… – Continue reading
When it comes to the topic of offshore corporations, some people immediately think of illegal tax shelters, but that is not the case. Currently, the IRS is working tirelessly to track down U.S. citizens and residents with unreported offshore income or assets and the new FATCA regulations make it virtually… – Continue reading
The “wall of Chinese capital” hitting property markets in Sydney and Melbourne will not ease up until the government introduces its anti-money laundering legislation, says an expert in ‘flight capital’. James Tee, an ethnic Chinese property developer whose business specialises in “capital expatriation” – that is, getting money out of… – Continue reading
A new treaty makes it more difficult for companies to take advantage of tax loopholes to avoid their financial obligations. Globally, initiatives are afoot to close tax loopholes and South Africa is one of the frontrunners – its new treaty with Mauritius removes the allure for tax-shy corporates doing business… – Continue reading
Almost all estate planning clients own real estate in one form or another – a residence, a vacation home, or rental property. Real estate presents unique challenges in estate planning because debt is often associated with the property and because it may be difficult (or not desirable) to sell the… – Continue reading
Introduction The UK Finance Act 2015 received royal assent on March 26 2015. This included final legislation for the introduction of a capital gains tax charge on non-residents who dispose of UK residential property. The new charge applies to such disposals made on or after April 6 2015. This update… – Continue reading
The verities of international tax law are no more. The days of strong residence-based rules of corporate taxation are numbered. The age of the Permanent Establishment (“PE”) as the central concept of international tax is drawing to a close. That seems to be the message from the OECD International Tax… – Continue reading
Government data suggests there may be tax shenanigans going on in the city of Richmond, a situation that clearly is intolerable. Questions have been raised by a recent Vancouver Sun report by Douglas Todd about residents in the upscale neighbourhood of Thompson, located in northwest Richmond. Former Richmond mayor Greg… – Continue reading
Last year at this time, more than a dozen U.S.-based corporations were threatening to move their legal residence to foreign tax havens in a paper transaction known as an inversion. Facing a wave of public opposition, some corporations abandoned these inversion attempts—notably, drugstore chain Walgreens put its plans on ice,… – Continue reading
Newcomers to the United States on temporary visas may be unpleasantly surprised at the income tax consequences. A little advance planning with tax and immigration professionals can go a long way towards mitigating income taxes due. Many countries imposes taxes on income earned in that country (i.e., a territorial tax… – Continue reading
The UK tax system is about to experience one of its biggest ever upheavals. From April 2016, there could be two tax jurisdictions for income tax for the first time. We can’t definitively say what will happen yet, because the current Scotland Bill is still subject to negotiation – and… – Continue reading
The United States has been criticized on more than one occasion for failing to be a meaningful participant in the OECD’s multi-pronged initiative to address base erosion and profit shifting (BEPS). Some commentators have even gone so far as to accuse the United States of actively working against the BEPS… – Continue reading
EMPORIUM — The Cameron County School District Board of Directors was unable to pass a tax millage rate during their regular meeting held on Thursday evening. Despite voting four times on various rates, the board was unable to come to a consensus. Only seven members were present for the meeting,… – Continue reading
Pretoria — Government has gazetted the South Africa-Mauritius tax treaty which came into force at the end of May, said National Treasury. “This new treaty reflects changes in the tax policies of the two countries and is in line with international best practices to deal with tax abuse as outlined… – Continue reading
With less than seven weeks between signature on 13 November 2014 and entry into force on 22 December, the new DTA between Cyprus and Iceland set a new standard for timeliness. Like most of Cyprus’s recent double taxation agreements, the DTA closely follows the form of the 2010 OECD Model… – Continue reading
IRS News Release IR-2015-70 (April 10, 2015) contains helpful but not exhaustive information about the filing obligations of US citizens and resident aliens abroad. Taxpayers outside the United States can also find helpful information about US tax-filing obligations and related matters by visiting (1) the IRS page on YouTube; (2)… – Continue reading
International tax rules will soon change, but companies’ behaviour may change sooner. There will soon be fewer places for multinational companies and ultra-rich individuals to squirrel away money. In November leaders of the G20 are expected to adopt a full range of measures to curb the practices of base erosion… – Continue reading
In the last few years, particularly following the credit crunch, there has been a tangible focus on tax avoidance and clamping down on tax planning. Overnight, the rules of the game were changed and what was previously considered to be legitimate tax planning was condemned as being aggressive and morally… – Continue reading
Abstract Over the past 25 years, Cyprus has become the portal of choice for investment into and out of Russia and Central and Eastern Europe. The new Russian de-offshorization law, which took effect on 1 January 2015, will have significant implications for users of overseas structures. This article examines the… – Continue reading
The 11 European nations seeking a financial-transactions tax will meet Thursday in Luxembourg in a bid to decide how to design the measure, according to European Union officials. Participating states are wrangling over which trades to tax and who should collect revenue, according to planning documents obtained by Bloomberg News…. – Continue reading
Yesterday, on June 17, 2015, three state tax bills were favorably reported to the United States House of Representatives (House) by the House Judiciary Committee (House Judiciary) after considering each during a half-day markup. The bills that were advanced included: (1) the Mobile Workforce State Income Tax Simplification Act (Mobile… – Continue reading
On June 17, the House of Representatives Judiciary Committee approved the markup of three bills dealing with interstate tax rules in the United States on individual income tax, business activity taxes, and sales tax on digital goods. The Mobile Workforce State Income Tax Simplification Act is a bipartisan measure that… – Continue reading
Effective from January 1st next year, personal income tax in Hungary will be paid at a flat tax rate of 15%. Consequently, the standard withholding tax rate on all Hungarian securities (debt securities and equities) will also be reduced from the current 16% to 15%, says Clearstream Banking in a… – Continue reading
Alongside an imminent price rise in houses in Britain (The Economist) and several other factors to take into account in considering moving to Malta, your domicile status and subjectivity to UK inheritance tax should also feature in the picture. It is useful to know that neither permanently leaving the UK… – Continue reading
Effective from January 1st next year, personal income tax in Hungary will be paid at a flat tax rate of 15%. Consequently, the standard withholding tax rate on all Hungarian securities (debt securities and equities) will also be reduced from the current 16% to 15%, says Clearstream Banking in a… – Continue reading
The U.S. Model Income Tax Treaty (the U.S. Model Treaty) generally represents the United States’ opening position in treaty negotiations. As a result, when changes to the treaty are proposed, international tax practitioners should be aware of the potential impact those changes can have on their existing inbound U.S. structures…. – Continue reading
U.S. AIR FORCE ACADEMY, Colo. — A law signed by Colorado Gov. John Hickenlooper will allow some active duty Airmen who list their official home of record as Colorado to return Colorado as their legal residency without being obligated to pay state income taxes for their military pay. The Colorado… – Continue reading
THE new double-tax treaty between SA and Mauritius is set to come into force in January next year, following a controversial renegotiation to better protect the South African tax base. However, tax experts have warned that sweeping changes to the treaty, including withholding taxes for interest (10%) and royalties (5%)… – Continue reading
Whether a UK taxpayer is classed as Scottish for the purposes of the Scottish rate of income tax (SRIT) will depend on whether that person is resident in Scotland in any particular tax year, according to draft guidance published by HM Revenue and Customs (HMRC). The SRIT will take effect… – Continue reading
The Haifa District Court is considering whether Ofer was an Israeli resident in 2006-2010. The Israel Tax Authority is demanding payment of NIS 940 million from the estate of billionaire Sammy Ofer, who passed away on June 3, 2011 at the age of 89, according to an order issued by… – Continue reading
Report on ‘poor’ neighborhoods full of mansions sparks calls for tax enforcement, residency documentation OTTAWA — The Canadian government takes a “zero tolerance” stand on tax evaders and is currently conducting audits on property owners in B.C., according to the Canada Revenue Agency. But Vancouver immigration lawyer Samuel Hyman said… – Continue reading
Dubai: The word offshore banking often evokes quite a number of unsavoury connotations. It’s associated with tax evasion, money laundering and high-level of secrecy, but the truth is that anyone can open an offshore bank account and it’s completely legal. Most expatriates set up a bank account offshore to protect… – Continue reading
Part I of this series of articles reviewed some of the basic tax requirements for using trusts to split income, Part II discussed a number of tax planning opportunities that can be accessible through the use of trusts, and Part III reviewed traditional testamentary trust income splitting planning and the… – Continue reading
Maryland residents who pay income tax to other states may be entitled to a refund of local income taxes paid in prior tax years. The U.S. Supreme Court in Comptroller of the Treasury of Maryland v. Wynne et ux. recently affirmed a Maryland Court of Appeals ruling that the state’s… – Continue reading
Hong Kong, as a world financial centre, will undertake legislative changes to implement automatic exchange of information of account holders Exchange of information is a recognised tool to enhance tax transparency and combat cross-border tax evasion. As a major financial centre, Hong Kong is committed to following global standards. While… – Continue reading
An archaic rule in the UK tax system means non-domiciled individuals ( “non-doms”) can be born and raised in the UK and pay less tax than their UK citizen counterparts. A person inherits their domicile at birth. Non-dom status will be triggered where a person’s father or grandfather was born… – Continue reading
Proposed Amendments To Cyprus’s Assessment And Collection Of Taxes Law The Cyprus Government has published a draft law amending the Assessment and Collection of Taxes Law (Law 4 of 1978) in order to facilitate implementation of agreements for automatic exchange of information with other countries. When it is enacted, the… – Continue reading
08/06/2015 – Pushing forward efforts to boost transparency in international tax matters, the OECD today released a package of measures for the implementation of a new Country-by-Country Reporting plan developed under the OECD/G20 BEPS Project. The Country-by-Country Reporting Implementation Package will facilitate a consistent and swift implementation of new transfer… – Continue reading
According to the Urban Dictionary a “New York minute” is an instant – the time between when the light changes and the car behind you honks its horn. If a New York minute is less than a minute, can a New York day be less than 24 hours? In the… – Continue reading
Chief prosecutor for canton’s decision to investigate despite inaction by other Swiss regulators shows power struggle within establishment The £28m HSBC will pay in “compensation” to the Swiss authorities following a money laundering investigation may be no more than a drop in the lake for Europe’s biggest bank, but it… – Continue reading
A COMMON REPORTING STANDARD ACROSS THE WORLD The goalposts in international tax reporting are moving rapidly. In conjunction with the G20, the OECD developed the Common Reporting Standard (CRS) as a global standard for the automatic exchange of information. This was approved by the OECD Council on 15 July 2014… – Continue reading
