Category: Residency

‘I was terrified we’d lose all our money’: banks tell US customers they won’t work with Americans

Thousands of Americans abroad are giving up their citizenship as the implementation of a complex new tax law causes banks to shut down accounts for US expatriates Angry Canadians are rare. But Patricia Moon qualifies. Until 2012, Moon was actually an American – albeit one who had lived in Canada… – Continue reading

NZ banks baulking at global FATCA style initiative to combat tax evasion; Lobby group says the later we adopt it the better

All is likely to be revealed on whether New Zealand will be an early adopter of the multilateral follow up to the controversial United States Foreign Account Tax Compliance Act (FATCA) in November, with late adoption something that would please the local banking sector. Either way it’s a question of… – Continue reading

Cyprus: Implications Of Anti-Avoidance Amendments To EU Parent-Subsidiary Directive

Cyprus transposed the EU Parent-Subsidiary Directive1 into domestic legislation when it updated its tax laws in preparation for EU membership in 2004. The Income Tax Law and the Special Contribution for the Defence of the Republic Law provide a liberal system of double taxation avoidance, which also extends to non-EU countries,… – Continue reading

Fears over tax loophole as Scottish independence could see thousands of wealthy people start claiming ‘non-domicile’ status

Non-doms would only have to have a father born in Scotland, expert warns Status only worthwhile for those with assets worth several million Scottish independence could see thousands of wealthy people start to claim ‘non-domicile’ tax status, experts predict. Mark Davies, a tax expert at website Nondom, said: ‘To claim… – Continue reading

United Kingdom: Recent Chinese Tax Changes Affecting The Shipping Industry

On 1 August 2014, the “Provisional Measures on the Collection of Tax on Non-Resident Taxpayers Engaged in International Transportation Business” (2014 No.37 Notice, the “New Regulations”) came into force. The New Regulations could have a significant impact on owners as they seek to streamline and tighten up the regulations in respect of… – Continue reading

Vanuatu declares former Chinese citizen stateless

A former Chinese citizen, Ruihua Yau, has been declared stateless by the Vanuatu government. The Secretary General of the Citizenship Commission, John Enock Ware, has confirmed that the agency revoked Mr Yau’s certificate of Vanuatu citizenship last month. Mr Ware says the Commission found Mr Yau got Vanuatu citizenship after… – Continue reading

Millions of Americans in Canada downplay links to Uncle Sam

With the Canadian government’s decision to comply in July with a Washington tax crackdown on “U.S. persons” around the world, many Ameri-Canadians are feeling rising anger, fear and even hatred toward their powerful country of origin. That said, the self-identities of Americans in Canada have been more ambiguous than they… – Continue reading

Who owes where?

This article was first published in the 2nd quarter 2014 edition of Personal Finance magazine. Your tax liability in the country in which you live and/or work depends on the tax laws of that particular country. Countries can levy taxes on a residence basis, because you live in the country,… – Continue reading

The cost of cutting ties with Uncle Sam soar: Tim Harper

Americans living in Canada are in a rush to renounce their citizenship in the face of Washington’s invasive tax grab. OTTAWA – Thomas Jefferson is famously believed to have defined the price of freedom as eternal vigilance. The price of freedom from Uncle Sam is a lot steeper. Faced with… – Continue reading

Senate Hopeful Defends Role in Irish Firm’s Merger

Years before Burger King sized up a Canadian headquarters in a hunt for lower taxes, Republican U.S. Senate candidate Mike McFadden’s investment firm was involved in a merger that moved an American pharmaceutical company to Ireland and significantly dropped its tax rate. McFadden’s Minnesota-based firm made more than $11 million,… – Continue reading

Facing up to Fatca

This article was first published in the 2nd quarter 2014 edition of Personal Finance magazine. Most people accept that they have to pay taxes in their country of residence. But citizens of the United States and green card holders who live outside that country – even if they have never… – Continue reading

United States: FATCA’s Impact On Preparing Trusts With Offshore Business or Investment Activities

The Foreign Account Tax Compliance Act (FATCA) was enacted into law as part of the Hiring Incentives to Restore Employment (HIRE) Act of 2010. Its purpose was designed to prevent U.S. taxpayers from “hiding” under the cover of a foreign based entity or trust in evading U.S. income tax and… – Continue reading

The Global Crackdown on Profit Shifting

CFOs of multinationals need to prepare by assessing how much their companies engage in profit shifting to cut their taxes. Do you have responsibility, whether direct or dotted line, for the tax function in your company? Does your company have, or plan to have, operations outside the United States? If… – Continue reading

Billionaire Eugene Melnyk: I’m a ‘whistleblower’ on tax allegations against Valeant

MONTREAL • Eugene Melnyk, the billionaire owner of the Ottawa Senators and founder of drug maker Biovail Corp., is waging war against the company that now controls his one-time business. Mr. Melnyk alleges that Valeant Pharmaceuticals International Inc. is masquerading as a Canadian company to make use of this country’s… – Continue reading

Global Tax Topical Focus – Corporate Inversions FAQ

To some, US companies switching their tax residency to gain a tax advantage are economic “traitors.” To others, they are victims of a United States tax code that effectively punishes them for investing at home and encourages them to look for opportunities overseas. In this Tax-News Topical Focus, we try… – Continue reading

Stock options in an international context: treatment of an indemnity for waiving stock options, received by a corporate officer within the meaning of the tax treaty between France and the United Kingdom

In its October 4, 2013 decision, no. 351065, Mr. Clive Worms, the French Administrative Supreme Court reiterated that, under domestic tax law, an indemnity received by a French tax resident in compensation of his cancelled stock options qualifies as a compensation for work. On the day the options were granted, the… – Continue reading

Here come the tax acronyms; FATCA, AEOI, specified US persons & the potential for a tax residence licence in your wallet alongside your driver’s licence

Here come the tax acronyms; FATCA, AEOI, specified US persons & the potential for a tax residence licence in your wallet alongside your driver’s licence Posted in Personal Finance April 15, 2014 – 07:22am, By Gareth Vaughan First we get FATCA then we’ll get AEOI. Apologies for the acronyms. FATCA… – Continue reading