In a five-to-four decision, the United States Supreme Court held that the dormant commerce clause protects in-state residents from the double taxation of their interstate income. This is a complicated decision and the margin favoring the taxpayers was razor-thin, one vote. The decision is complicated because the tax involved was… – Continue reading
The Income Tax Department will retain the detailed questions on foreign assets and income of resident Indian citizens… The Income Tax Department will retain the detailed questions on foreign assets and income of resident Indian citizens in the revised tax return forms, to be issued shortly. The relaxation announced by… – Continue reading
With the Swiss government signing a landmark Automatic Exchange of Information (AEOI) agreement with the European Union (EU) last week, efforts are underway for a similar bilateral pact with India. The effort, which is expected to provide a strong impetus to the Narendra Modi government’s pitch to combat the black… – Continue reading
Presidential candidates must come clean on America’s highly controversial global tax law – and more must urgently be done to repeal it, not least because it is “a blue print for worse to come”, warns the boss of one of the world’s largest independent financial advisory organisations. Nigel Green, founder… – Continue reading
Capital gains tax charges from 6 April 2015 The scope of capital gains tax (CGT) has been extended and now applies to gains arising on the sale of UK residential property by non-UK tax residents (non-residents). Only gains arising after 5 April 2015 are subject to the new charge as… – Continue reading
It is not uncommon for affluent families from certain countries to maintain offshore structures to hold a portion, and often times a significant portion, of their wealth. The reasons for holding assets outside of their country of residence are many, and such assets are frequently held in foreign corporations. As… – Continue reading
Portugal can be a very attractive country to live in from a tax point of view. The inheritance tax regime is very benign here, and there is no wealth tax. Tax efficient arrangements can lower tax liabilities on your investment and pension income. And if you are a new resident,… – Continue reading
Many UK expats based in Portugal have retained their trusts, even though the Government introduced a tax of 28% on trust distributions from 1 January 2015. Despite the existence of several planning options, including an offshore bond, Jason Porter, director at advisory firm Blevins Franks, said many clients remained unaware… – Continue reading
Peter Scully writes: From 6 April 2015 there will no longer be tax advantages for non-UK residents who invest in the UK residential property market. These changes have seen Capital Gains Tax (CGT) exemption being removed along with restricted access to Private Residence Relief (PRR) as well as the potential… – Continue reading
It’s been called mysterious, secretive, and shadowy, but when it comes to the so-called shell company created by former president Bill Clinton as a vehicle for the delivery of consulting services, there’s a whole lot less there than meets the eye. According to the Associated Press, in 2008, Clinton set… – Continue reading
Investments Derived From Structural Reforms The approved structural Reforms are an unprecedented opportunity for a transformational economic growth in Mexico, being the most relevant from an investment point of view the reforms related to Energy, Telecommunications and Antitrust, which have put Mexico in the radar of Multinational companies seeking to… – Continue reading
The first fiscal amendment of the Juan Carlos Varela government was passed earlier this month on May 4, by Law 27 of 2015. Here are two important pointers of the fiscal reform: 1. TAXABLE INCOME PRODUCED IN PANAMA Article 694 of the CF originally included as taxable income the income… – Continue reading
Non-Resident Indians (NRI) constitutes a significant portion of buyer percentage when it comes to real estate transactions in India. Irrespective of constituting a considerable portion, they still face a lot of hassles in the process of taxation when buying or selling properties. Rajan Pillay representing his client who is an… – Continue reading
On May 20, 2015, the US Department of the Treasury released for public comment draft updates to the US Model Income Tax Convention, including provisions to deny treaty benefits to companies that change their tax residence via inversion transactions. The Treasury said other changes are intended to ensure that the… – Continue reading
LONDON, May 22 (Reuters) – One hallowed feature of Britain’s finances is a tax break for individuals called “non-domiciled status.” The break, which is more than 200 years old, is designed to attract foreign investors by allowing them to keep wealth they make abroad out of the reach of the… – Continue reading
India has amended section 6 of the Income Tax Act to introduce place of effective management (POEM) as the test to determine the place of residence of companies in the country. The change was included Finance Act, 2015, which received the President’s assent on May 12, 2015. The change will… – Continue reading
INTRODUCTION On May 5, 2015 the Swiss Federal Supreme Court held a public hearing about two cases relating to the reclaim of Swiss withholding tax (WHT) in connection with arbitrage cases and issued its long awaited decisions. Two Danish banks issued the question on treaty entitlement for the refund of… – Continue reading
Maryland’s taxation policy violated the U.S. Constitution by taxing income that state residents earned in other states, the U.S. Supreme Court ruled on Monday. The nation’s apex said the state’s controversial policy imposed form of double taxation on residents. The court in its ruling said Maryland cannot impose form of… – Continue reading
In 1934, a distinguished American jurist, Judge Learned Hand, famously opined that “one may so arrange his affairs so that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to… – Continue reading
In July 1997, Tyco International (with then Wall St darling Dennis Kozlowski at the helm) was “acquired” by a relatively small provider of home security services, known as ADT Inc. The deal arguably exploited some strategic synergies between the two companies, but far and away the biggest benefit to Tyco… – Continue reading
The advantages of off-shore investments Two of the top reasons that South African investors are given to encourage offshore investments are that going offshore diversifies your portfolio and that it gives you access to sectors you could never find on the resource-heavy JSE. “While those are not reasons to be… – Continue reading
The bipartisan Mobile Workforce State Income Tax Simplification Act, which which would simplify tax reporting requirements for those workers employed in multiple state US jurisdictions, has been introduced into the House of Representatives by Hank Johnson (D – Georgia) and Mike Bishop (R – Michigan). States currently have widely varying… – Continue reading
THE BJP-led National Democratic Alliance government, which had made a lot of noise about black money and the illegal stashing of funds abroad in the run-up to general elections last year, finally got down to some serious work to tax ill-gotten wealth and curb its growth. Last week, the government… – Continue reading
This note is intended as an introduction to inheritance tax (IHT) issues that need to be covered where a “non-dom” (an individual domiciled outside the UK) is planning on becoming resident in, or is already resident in, the UK. It should be emphasised that this is a complex subject, and… – Continue reading
“Uruguay has now definitely earned its long-time nickname — the Switzerland of Latin America.” That’s what I wrote several months ago during my first visit to this small, south Atlantic costal country wedged between Brazil and Argentina. For the last week, I have been enjoying my second visit to Uruguay,… – Continue reading
As of 6 April 2015, non-UK residents will no longer benefit from attractive tax advantages when they invest in the UK residential property market. The tax changes include the removal of the Capital Gains Tax (CGT) exemption, restricted access to Private Residence Relief (PRR) and possible removal of personal allowance… – Continue reading
PART I – CAPITAL GAINS TAX If you are thinking of doing a Will, or you are the executor of a deceased estate, it is important to consider what taxes and duties may be payable by the estate or the beneficiaries when the time comes for an executor to deal… – Continue reading
Shayne Nelson, Chief Executive Officer of Emirates NBD, muses how corporate governance, risk and compliance have changed beyond recognition since he first came to the region. Shayne Nelson has seen a lot of change in his extensive banking career, which has spanned several continents. With roles including Chairman of Standard… – Continue reading
NEW DELHI: Ahead of Prime Minister Narendra Modi’s visit to South Korea this month, the Cabinet today approved revising the double tax avoidance pact with Seoul to provide tax stability and facilitate flow of investment and technology between the countries. The Cabinet headed by the Prime Minister gave its approval… – Continue reading
The Central Board of Direct Taxes [CBDT] on 26th March 2015 issued a Circular no. 4/2015 wherein they have clarified that while interpreting the provisions of Section 9(1)(i) of the Income Tax Act, 1961 [herein after referred to as ‘Act’] read with Explanation 5 inserted to the said section by… – Continue reading
In the 2015 Budget Speech presented to the National Assembly on 25 February 2015 the Minister of Finance announced that amendments will be proposed to change the rules for the digital economy in line with the latest guidance issued by the Organisation for Economic Co-operation and Development (“OECD”) in its… – Continue reading
The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project is changing the international tax landscape by building a new international consensus on how to tackle BEPS. In September 2014, the first seven of the deliverables under the 15-point BEPS Action Plan were presented to G20 Finance Ministers when they met… – Continue reading
As discussed in our previous briefing, Labour calls time on the remittance basis, Ed Miliband has announced a policy of abolishing what he called the “non-dom tax regime”, to be implemented in the event of a Labour victory in the coming election. Many individuals who are UK resident but non-UK… – Continue reading
Most people have heard of the Organisation for Economic Co-operation and Development (OECD) and are probably aware it wants to make the world a “better” place. Its work is probably of little interest to most companies based in the UK. But this would change if constitutional arrangements between Scotland and… – Continue reading
Athens: Greek authorities arrested one of the most important businessmen in the country, Leonidas Bobolas on Wednesday, for tax evasion. He was released later after paying €1.8 million in back taxes. This is just one of the Greek government’s attempts to collect money from tax evaders. In Greece, income tax… – Continue reading
The new omnibus bill presented by the Greek ministry of finance will be tabled in parliament on Thursday in order to expedite negotiations with creditors and reach an intermediate deal. The new bill includes several measures and reforms such as methods of tackling tax evasion, revenue increase from value added… – Continue reading
Starting with 1 June 2015, non-resident taxpayers earning interest income from Romania are allowed to apply the same tax treatment as resident taxpayers. The change in the law results from a European Commission infringement procedure against Romania regarding the discriminatory treatment applied to non-resident legal entities compared to resident taxpayers…. – Continue reading
“Why are we doing this to folks? Why are we tormenting them in this way?” IRS Taxpayer Advocate Nina Olson asked in an address to Securities Industry and Financial Markets Association FATCA Policy Symposium in Washington last year. These “folks” are Americans living abroad: NGO workers, English teachers, physicians, taxi… – Continue reading
India’s rupee rose for a second day as the dollar weakened and global funds resumed purchases of local bonds after the government sought to clear uncertainties over a retrospective tax on capital gains. Overseas funds bought a net $130 million of local-currency notes on April 24, the latest figures show,… – Continue reading
According to the most recent estimates, the quantity of goods carried by containers has risen from around 100 million metric tons in 1980 to about 1.5 billion metric tons in 2012. Out of these numbers, one container in every 11 that is engaged in global trade is either bound for… – Continue reading
Yesterday afternoon, the Canadian government tabled the 2015 Canadian Federal Budget. Two measures are particularly relevant to certain employers. Withholding Relief for Non-Resident Employers and Employees To take effect next year (if the measure is enacted), Budget 2015 proposes an exemption from certain withholding requirements on payments from “qualifying non-resident… – Continue reading
Republicans and other people who are opposed to immigration reforms claim that they are a burden on the national economy and its resources. But latest reports suggest that undocumented immigrants paid as much as $12 billion dollars as taxes at state and national level. This is a huge amount and… – Continue reading
Benchmarks are poised just above their 200-day moving average — a long-term support April 25, 2015: Both the Sensex and the Nifty are very tantalizingly poised just above a long-term support level. This adds zing to next week’s trading that is expected to be full of action thanks to the… – Continue reading
About 11.4 million undocumented immigrants in the U.S. paid nearly $12 billion in state and local taxes in 2012, and granting them lawful permanent residence would further increase total tax collected, a study revealed. The recent study made by the Washington-based Institute on Taxation and Economic Policy said the average… – Continue reading
Britons overseas are now subject to CGT when selling UK properties, but this straightforward advice could help minimise the impact Expats who have kept a house or flat in Britain need to act now to avoid being stung by a hefty capital gains tax (CGT) bill in the future. Since… – Continue reading
Fond du Lac County Treasurer’s Office is notifying the public that the Wisconsin Department of Revenue is auditing the 2014 Lottery and Gaming Credits claimed within Fond du Lac County. The Treasurer’s Office has mailed information to those individuals who may be affected by this audit. Those individuals are asked… – Continue reading
The arrival of Netflix in Australia has brought into sharp relief the GST base erosion problem caused by global digital commerce. Along with the non-taxation of low-value imported goods, the absence of GST on services and digital products imported by consumers represents an omission from the tax base that is… – Continue reading
TL: What are the main considerations and advantages for doing business in Malta? AB: Malta’s positive approach to business promotion, development and standard of living within the EU makes the island a destination of choice for relocation of business purposes. Malta offers noteworthy benefits to individuals and investors who are… – Continue reading
Without doubt, the most important milestone in Finance Minister Joe Oliver’s 2015 budget is that the federal government will finally be in the black after facing deficits ever since the 2008-09 Great Recession. Not many advanced countries have achieved this badge of fiscal prudence, which will have untold benefits for… – Continue reading
The double tax treaty signed on September 17th 1970 between the Grand-Duchy of Luxembourg and the Kingdom of Belgium (the “DTT”) provides in its article 15 that employment income derived by a resident of a contracting State in respect of an employment exercised in the other contracting State is in… – Continue reading
