The Irish Government has published an update on its International Tax Strategy, in which Finance Minister Michael Noonan stresses that the country is “well positioned for the post-base erosion and profit shifting (BEPS) world.” According to Noonan, “This is not something that has happened by accident. Difficult but necessary changes… – Continue reading
JAKARTA, Oct 19: As ‘tax-havens’ are now routing some 60 per cent of international trade, multinational corporations (MNCs) have become more aggressive in evading taxes. As the volume of global trade was estimated at $23.5 trillion in 2013, of which $18.5 trillion was trade in goods and the rest was… – Continue reading
Golden visa EU citizens may freely register as residents in Portugal. However, non-EU citizens may also obtain residence in Portugal if they obtain a ‘golden visa’ by participating in investment activity and fulfilling certain requirements. Requirements Obtaining a golden visa requires one of the following types of investment: acquisition of… – Continue reading
In just over two months, thousands of U.S.-based financial institutions will face new requirements for sharing financial information. These businesses should get ahead of the deadline and start preparing for the impact these rules will have on their operations and bottom lines. The Organisation for Economic Co-operation and Development’s new… – Continue reading
This summer brought some very significant amendments to the Cyprus tax laws, further enhancing Cyprus’ favourable tax regime. On 17 July 2015, the following laws were amended: The Special Defense for Contribution law No. 117(I) of 2002 as amended; The Income Tax Law No 118(I) of 2002 as amended; and… – Continue reading
Individuals and families whose tax plans include trusts should take note of the recent decision of the Supreme Court of Newfoundland and Labrador in Discovery Trust v Minister of National Revenue (“Discovery Trust”)1 – the first case to deal with the issue of the residency of a trust for provincial… – Continue reading
Information on Completing the Form 8802, Application for United States Residency Certification Many U.S. treaty partners require the IRS to certify that the person claiming treaty benefits is a resident of the United States for federal tax purposes. The IRS provides this residency certification on Form 6166, a letter of… – Continue reading
THE ADVANTAGES OF JERSEY For high net worth individuals considering a relocation, there are a number of factors that will be weighed up in making a choice which is right for both the head and the heart. To be a serious contender, a jurisdiction must certainly be fiscally friendly. But… – Continue reading
In brief On 18 September 2015, Treasury released exposure draft legislation in relation to the implementation of the Organisation for Economic Co-operation and Development’s (OECD) Common Reporting Standard (CRS) for the automatic exchange of financial account information. The CRS is intended to reduce international tax evasion and represents the next… – Continue reading
The location of a holding company is a significant consideration in any international corporate structure. Choice of jurisdiction for a group holding company (‘Holdco’) is relevant both from the point of view of tax optimisation (maximising withholding tax free dividend, interest and royalty flow up through the group and minimising… – Continue reading
For many years international tax planning for Russian inbound and outbound investments, and wealth planning for Russian resident individuals, was rather straightforward. That was primarily due to relatively simple domestic tax rules and a degree of inexperience amongst the Russian tax and other interested authorities in relation to international tax… – Continue reading
The Council of Ministers has approved an agreement between the Republic of Turkey and Republic of Kosovo (“State” or collectively “States”) to prevent tax evasion and double income taxation for residents of the two countries (“Agreement”). On 19 August 2015, the Council of Ministers approved the Agreement and its annexed… – Continue reading
Writing exclusively for SuperyachtNews.com, Patrick Maflin, of Marine Accounts, advises crewmembers on how best to avoid falling foul of the UK/ SPAIN Double Taxation Agreement… The Seafarers Earnings Deduction (SED) is arguably the taxation scheme of choice for most Seafarers nowadays working on foreign going yachts. It is open to… – Continue reading
With the final draft of the OECD’s BEPS initiative – Base Erosion and Profit Shifting – out later today, the taxman’s ability to tax international transactions as well as those of foreign firms operating in India will go up dramatically; the idea behind the initiative is to treat all cross-border… – Continue reading
It is estimated that only around 1% of the world’s population have two or more passports, making dual citizenship an exclusive privilege JOHANNESBURG – “No man is an island” is the theme of this year’s upcoming Investment Agenda, being held in Johannesburg on the 20th of October. Leading investors, asset… – Continue reading
Efforts to block the exchange of information on US taxpayers’ foreign accounts are halted as an Ohio federal judge says Sen. Paul and six others don’t have standing to challenge parts of the Foreign Account Tax Compliance Act, reports BNA. US District Court for the Southern District of Ohio Judge… – Continue reading
George Osborne’s plans to tighten tax rules for wealthy foreigners living in Britain will leave many offshore trusts outside the UK tax net, according to proposals published on Wednesday, reports the Financial Times. The Treasury’s consultation on “carefully targeted” changes to the rules for “non-doms” — people who live in… – Continue reading
The OECD has said that its base erosion and profit shifting (BEPS) project will create policy challenges for Ireland, but the nation should emerge well placed to attract foreign direct investment, reports Tax News. The report states: “Given the strong presence of intellectual property-intensive information technology and pharmaceutical companies in… – Continue reading
If you are a foreign executive moving to the United States for work, not only do you have to consider practical concerns like moving your family and finding a new residence, but you also need guidance as to any US tax implications stemming from the move. One of the first… – Continue reading
India must align domestic laws with international treaties A recent ruling of the Punjab & Haryana High Court (HC) in the Serco BPO case has once again underlined the need for consistency between tax policies and the jurisprudence that evolves around it, thus, leaving little to interpretational hazards. The HC,… – Continue reading
Thousands of Australians head offshore each year to expand their horizons and a lucky few will fund their adventure by working overseas. Some may live overseas and work for an extended period. There can often be confusion about the tax implications for taxpayers who take advantage of such offshore opportunities…. – Continue reading
Tax residency of Jersey companies Jersey companies may (contrary to the default position) be treated as exclusively tax resident in jurisdictions other than Jersey pursuant to Article 123(1)(a) of the Income Tax (Jersey) Law 1961. The criteria for a Jersey incorporated company to be resident (for taxation purposes) in a… – Continue reading
The IRS has let Americans living abroad wrongly claim tax credits on their foreign income, according to a new report from the agency’s watchdog. The Department of Treasury’s inspector general for tax administration said the IRS allowed taxpayers to wrongly claim around $95 million between 2010 and 2012 in foreign… – Continue reading
The Australian Government has released an exposure draft of the legislation implementing the OECD Standard for Automatic Exchange of Financial Account Information (known as the Common Reporting Standard, or CRS), and an accompanying explanatory memorandum (available here). The draft requires Reporting Financial Institutions to report to the Commissioner of Taxation… – Continue reading
A new wave of global tax compliance regulation is a game changer in the way asset owners and investment management companies report activities. Globalization of financial markets has made it increasingly simple to make, hold and manage investments outside an asset owner’s own tax domicile. A standard on automatic exchange… – Continue reading
1. What is CRS? “CRS” or Common Reporting Standard is a regime developed by the OECD to facilitate and standardise the exchange of information on residents’ assets and income, primarily for taxation purposes, between numerous jurisdictions around the world. Officially referred to as the OECD Standard for Automatic Exchange of… – Continue reading
More than 90 jurisdictions, including all 34 member countries of the Organisation for Economic Co-operation and Development (“OECD”) and the G20 members, have committed to implement the Common Reporting Standard for automatic exchange of tax information (“CRS”). Building on the model created by FATCA, the CRS creates a global standard… – Continue reading
Some Italian parliament members published a proposal for a new law that may dramatically change the scenario for e-commerce and web operators doing business in Italy. The proposal (called by some commentators as “Digital” or “Web Tax”) is substantially a combination of domestic rules affecting the taxation of the digital… – Continue reading
Under the I-T Act, 1961, taxpayers are broadly categorised as Ordinary Resident, Not Ordinarily Resident (NOR) and Non-Resident (NR). Reporting and paying taxes on overseas incomes and assets come with their own set of challenges. Under the I-T Act, 1961, taxpayers are broadly categorised as Ordinary Resident, Not Ordinarily Resident… – Continue reading
The question for many expats is in Australia is if switching their UK pension to a Qualifying Recognised Overseas Pension Scheme (QROPS) is worthwhile? Tax is a personal issue and no one-size-fits-all solution is available, but here are some general pointers to how pensions are taxed in different financial centres… – Continue reading
Administrators of tax-qualified retirement plans (or their delegated payor) are responsible for both withholding on distributions and for reporting the tax withheld. If taxes are under-withheld, the administrator/delegated payor may be subject to penalties. Although the rules governing withholding on distributions to US citizens and resident aliens are clear and… – Continue reading
An increasing number of Americans renounced their citizenship and cut-off long term residencies during the initial three months of 2015 due to a crackdown in the foreign tax rules. The exit wave went down a little in the second half, but has continued. The Internal Revenue Service and Treasury Department… – Continue reading
It may be a common misunderstanding that a U.S. citizen or permanent resident (Green Card holder) can give up their citizenship or surrender their Green Card and then as a non-U.S. taxpayer make gifts or pass their estate to U.S. taxpayers free of estate and gift tax. The IRS recognized… – Continue reading
The EB-5 Visa program has been widely promoted as a legal basis for foreign business owners to gain conditional residency followed by permanent residency in the United States. The program is a great solution to the proposition “I want to live in America.” The decision to become a permanent resident… – Continue reading
The recent shocks in the global economy triggered by the Chinese devaluation of yuan and its economic slowdown are likely to dominate discussions in the two-day meeting of G20 Finance Ministers and Central Bank Governors starting here tomorrow over which India has expressed serious concern. Finance Minister Arun Jaitley arrived… – Continue reading
Stanley Amland threw it off. So did Ingrid Bracke. Rhoda May Derksen ditched hers, too. The names, picked at random for this article from the Federal Register, are among the 3,415 Americans who renounced their U.S. citizenship or relinquished their residency permits last year. As a national debate rages about… – Continue reading
International worldwide transactions in Mexico face a weakness as a result of an old and outdated provision which disallows for income tax purposes, the deduction of payments made abroad on a prorated basis with other parties that are not subject to Mexican income tax, such as foreign residents with no… – Continue reading
Rejecting “treaty shopping” claims, India’s High Court of Punjab and Haryana has ruled that India should not tax capital gains from the sale by Mauritian entities of shares held in an Indian company if they are proven resident in Mauritius. The ruling was given in Serco BPO Private Limited v…. – Continue reading
Stanley Amland threw it off. So did Ingrid Bracke. Rhoda May Derksen ditched hers, too. The names, picked at random for this article from the Federal Register, are among the 3,415 Americans who renounced their U.S. citizenship or relinquished their residency permits last year. As a national debate rages about… – Continue reading
The Foreign Account Tax Compliance Act (FATCA) requires, in essence, that U.S. citizens who reside outside the U.S. disclose to the IRS all of their foreign banking assets including retirement plans, savings accounts, etc. It also requires foreign banks to assist the IRS in applying the disclosure rules or else… – Continue reading
It’s a decision that could spell relief for many Mauritius based investors. This week the Punjab & Haryana High Court has re-iterated that a Mauritian tax residency certificate is sufficient to avail treaty benefits. Senior advocate Porus Kaka tells CNBC TV18’s Menaka Doshi that this re-iteration is important given the… – Continue reading
Reevaluating reporting options and investmentsSmart choices and targeted investments today may help contain the approaching resource crunch and the long term costs of compliance FATCA has placed tax reporting front and center with management committees of financial institutions, but it represents just the tip of a potentially larger iceberg. Legislation… – Continue reading
Tightening noose on tax evaders, the government and the Income Tax department will keep a closer eye on those with foreign assets and income, which even includes the negligible interest earned on bank deposits, small earnings while on a short trip abroad or even an online project that paid you… – Continue reading
Security fears; Global authorities to begin sharing sensitive data If you have a bank account somewhere overseas, that information will make its way back to the Canada Revenue Agency (CRA) in a couple of years. In 2018, international tax authorities will begin automatically sharing financial information under the terms of… – Continue reading
Next week, G20 finance ministers and central bank governors will gather for their third meeting during Turkey’s presidency. With just two and half months until leaders assemble in Antalya for this year’s summit, these meetings give the G20 an opportunity to confirm 2015 outcomes and demonstrate that the G20 remains… – Continue reading
Despite some recent evidence that the natural forces of supply and demand are seeing some application of the brakes on the accelerating housing market, there is still concern about its speed. As we all hurtle along the highway to housing hell (or heaven, depending on your circumstances), the Government’s proposed… – Continue reading
In a recent decision (CAA Versailles, July 8, 2015, n°13VE01079), the Versailles Administrative Court of Appeals (CAA) provided an interesting illustration of the operation of the specific anti-abuse provision (i.e., different from the general abuse of law theory) attached to the dividend withholding tax exemption provided, in accordance with the… – Continue reading
The U.S. and China enjoy increasingly strong connections. Yet virtually no Chinese family or business relishes dealing with the Internal Revenue Service (IRS). American tax laws are famously complex, and dealing with the IRS can be like quicksand. Of course, whether they like it or not, U.S. citizens and green… – Continue reading
On 16 June 2015 the Department of International Tax Cooperation (the “DITC“) of the Cayman Islands government announced that it was moving forward with the implementation of the OECD Common Reporting Standard (“CRS“), via the introduction of Cayman Islands domestic law, by October 2015. The CRS represents a significant step… – Continue reading
Introduction In 1934 distinguished US 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
