Category: Residency

Worldwide: Governments Continue To Welcome Wealthy Foreigners

With the UK announcing new tax rules for foreigners living in the country, the government has been careful not to damage the country’s appeal to wealthy foreigners. The “non-dom” tax status “plays an important role in allowing those from abroad to contribute to our economy”, says George Osborne, the UK’s… – Continue reading

OECD releases three automatic information exchange reports

THE OECD has published three reports outlining the framework for the automatic exchange of financial information between governments as part of its efforts to curb tax avoidance and evasion. In October last year, the organisation announced the agreement to automatically share tax information on individuals by the year 2018, to… – Continue reading

Revenues surge as global crackdown on tax evasion gathers pace

Hundreds of millions of tax dollars are flooding into exchequers across the world, as governments offer evaders a last chance to own up to undeclared accounts, reports the Financial Times. Taxpayers with funds stashed offshore are coming forward voluntarily in their tens of thousands ahead of new transparency rules that… – Continue reading

Cayman Islands: FATCA – Taxing Issues For Self-Administered Funds

Maples and Calder and Maples Fund Services representatives explain how US and UK Fatca will impact Cayman-based funds. The implementation of the US Foreign Account Tax Compliance Act (US Fatca) and the less well-known but equally applicable UK equivalent (UK Fatca) have been a topical and core focus for Cayman… – Continue reading

Mauritius introduces new form for tax residency with more disclosure

MUMBAI: The Financial Services Commission (FSC) of Mauritius, which is the regulatory body for the Mauritian non-banking financial services sector, has introduced a new application form for obtaining a tax residency certificate (TRC). FSC verifies these applications and recommends issue of the Mauritius tax residency certificate by the Mauritius revenue… – Continue reading

Court Revokes Canadian Expat Voting Rights

As U.S. expats struggle with the IRS’s punitively strict tax reporting requirements, Canadian expats are now grappling with harsh government measures of their own. Ontario’s top court has ruled that Canadian expats who have lived abroad for five years should not be allowed to vote in federal elections because it… – Continue reading

Tax implications of setting up overseas subsidiaries

There is a rising trend that many start-ups incorporate their ultimate holding companies abroad, especially in Singapore for various reasons with tax being one of the top 3 factors for such decisions. Some of them have restructured the holding structures after few months of direct Indian holding to accommodate requests… – Continue reading

India: Indian Revenue Issues Clarifications On The Black Money Act

Black Money Act covers residents with undisclosed foreign assets and income and non-residents who have invested Indian-sourced income in offshore assets Compliance Scheme window open only till 30 September for declaring assets and until 31 December 2015 to pay tax at 30% and penalty at 30%. Revenue recommends disclosure of… – Continue reading

Pete McMartin: Was offshore real estate data staring us in the face all this time? : B.C. government already asks for proof of citizenship for property transfer tax exemption

The abiding complaint of those who believe offshore buyers are driving the rise in real estate prices in Metro Vancouver is the lack of data to prove it. How can you identify a problem if you can’t quantify it? The corollary to that complaint is the provincial government’s apparent inability,… – Continue reading

‘Strict liability’ move could penalise honest errors, CIoT warns

THE GOVERNMENT’S MOVE to introduce criminal ‘strict liability’ measures for those with undeclared offshore income and assets have been roundly criticised by the CIoT. While welcoming the announcement that the offence will be targeted at only the “most serious” offshore tax evaders and a threshold of £5,000 of under-declared tax… – Continue reading

Portuguese minister to be charged in money-laundering “golden” visa scandal

Lisbon: Portuguese prosecutors said on Thursday they plan to charge former interior minister Miguel Macedo for his role in a money-laundering scandal linked to “golden” visas, which handed residency permits to wealthy foreigners. The announcement came shortly after Portugal’s National Assembly decided to lift the parliamentary immunity Macedo enjoyed as… – Continue reading

Armenia renews treaty to exempt double taxation with Belarus

YEREVAN. – Armenia has renewed a treaty to exempt double taxation with Belarus during the Cabinet’s meeting on Thursday. In particular, the treaty envisages regulation of the residency of legal entities in the case of dual residency. The procedure for the exchange of information constituting bank secrecy has been specified…. – Continue reading

Define a tax haven, business lobbies tell government

Before going after multinationals that channel profits through tax havens and low-tax nations, you must define what one is, business lobbies have told the Abbott government. Treasurer Joe Hockey announced in the May budget that the government would be strengthening anti-avoidance laws to go after 30 companies with over $1… – Continue reading

New EU anti-money laundering rules to take effect from 26 June

A raft of reforms to EU anti-money laundering rules will come into force later this month after they were finalised and published in the official journal of the EU, reports Out Law. The fourth Anti-Money Laundering (AML) Directive will take effect from the 26 June. EU countries will have two… – Continue reading

Israel: Renewing Your US Passport? The IRS Will Know About It

Individuals who renew their US passport need to take into consideration that their Social Security Number (SSN) and country of residency will be forwarded to the IRS. Since July 2014, the passport renewal instructions forms have dedicated a specific paragraph detailing this new procedure: “Section 6039E of the Internal Revenue… – Continue reading

Irish with Swiss bank accounts will lose their secrecy – MEP

Irish citizens holding bank accounts in Switzerland will no longer be able to avail of the traditional secrecy pertaining to Swiss bank accounts, MEP Marian Harkin has said. The European Commission and Switzerland this week signed an agreement that is intended to clamp down on tax evasion. Both sides will… – Continue reading

Elite group of British-born residents enjoy ‘non-dom’ tax haven

At least 800 British-born United Kingdom residents enjoy “non-domiciled” status, a tax break intended for temporary residents, according to data released in response to a Freedom of Information Act request by Reuters. Lawmakers said the information highlighted the need to change the tax rules to ban so-called “hereditary non-doms”, where… – Continue reading

Malta dangles its citizenship for a price

As wealthy foreigners rush to get citizenship in Malta under a new programme, the residency requirement is taking many forms. Russians rent high-end villas, then stay in five-star hotels when they visit. An American financier plans to live in Switzerland but occasionally vacation in Malta. One Vietnamese businessman, eager to… – Continue reading

Malta’s credibility as financial centre takes another hit over battle for Gaddafi’s money

Malta’s credibility as a financial centre has taken another hit as news broke this week about a legal battle for the millions of euros accumulated by Mutassim Gaddafi – son of Libyan dictator Muammar Gaddafi – currently frozen in a Bank of Valletta account. Malta’s role in all this came… – Continue reading

Russian Federation: Russia’s Deoffshorisation: First Foreign Ownership Filing Deadline Approaching Swiftly

Ahead of their joint event on Deoffshorisation Compliance on 21 May, TMF Group’s Sub Regional Director for CIS and the Nordics Alex Medlock and Artem Toropov, Senior International Tax Associate at law firm Goltsblat BLP LLP (the Russian practice of Berwin Leighton Paisner), outline the key deoffshorisation/CFC compliance requirements and… – Continue reading

Tax Planning: Should Wealthy Clients Move?

“Location, location, location” the well-known real estate mantra, is a notion that advisors of high- and ultrahigh-net-worth clients might also want take to heart. “Residency drives how much sophisticated wealth structuring and asset protection you can do,” says Merrill Lynch advisor Adam Katz. While the concept that it’s better to… – Continue reading

Putin fishing to pull oligarchs’ cash back to Russia

President Putin coined a new word in his state of the nation address at the end of 2012, when he called for new measures for the “deoffshorisation of our economy”, reports the International Business Times. This was to become a major addition, not just to the Russian vocabulary but to… – Continue reading

Craig Elliffe: Multinationals face tax change

Bold step on non-resident levy likely to be first of many. A tax policy paper released yesterday proposes changes on the taxation of non-residents in respect of New Zealand-sourced interest income. These changes, if implemented, will affect large multinationals, banks and even individual New Zealand borrowers. As the first significant… – Continue reading

The conundrum of the interplay between interest deduction limitations, interest withholding tax and double tax agreements

The deductibility of interest has for years been a contentious issue and this has been reaffirmed with the introduction of section 23M into the Income Tax Act No 58 of 1962 (the “Act”) with effect from 1 January 2015. A further addition to the interest sphere of income tax is… – Continue reading

A place in the sun: Retiring overseas requires careful tax planning

Jason Porter explores the tax regimes in Portugal, France, Malta and Cyprus – four of the most advantageous territories for UK ex-pat retirees People aged 55 and over are now entitled to their pension in the form of a lump sum, to be taxed at marginal rates applying in the… – Continue reading

The President signed into law the dot. FATCA

Passing between tax administrations Polish and US information on accounts and income tax residents predicts signed by the president Bronislaw Komorowski law on ratification of the agreement with the USA on the use of so-called FATCA Act. As reported by the presidential office, in terms of the Act of 20… – Continue reading

Taxation in Spain

A guide to Spanish taxation in 2015 for expats, with up-to-date information on income tax, VAT, property tax and other taxes for residents and non-residents in Spain. If you are living and working in Spain, you will be liable to pay Spanish taxes on your income and assets and will… – Continue reading

Ireland: Private Client Tax Ireland

1. NON-TAX ISSUES 1.1 Domestic law 1.1.1 Briefly describe your legal system and its origins The legal system of the Republic of Ireland is a common law system. In order to ensure consistency, a legal principle developed whereby courts were generally required to follow earlier relevant decisions. This doctrine of… – Continue reading

Malta: Business, Investments And Residency Opportunities!

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

Taxpayer Advocate Urges IRS to Ease FATCA Rules for Americans Abroad

Doing so would get rid of ‘overlapping and duplicative disclosure requirements,’ says advocacy group for Americans abroad The IRS’ taxpayer advocate is urging the tax service to simplify rules for Americans living overseas. Currently, foreign bank accounts must be reported both to the Treasury, in a Report of Foreign Bank… – Continue reading

South Africa Guides On Corporate Residency

The South African Revenue Service (SARS) has issued a revised draft interpretation note that discusses the principles and guidelines for the considering the “place of effective management” in determining the tax residence of a company. SARS points out that the concept of residency is critical in determining a company’s South… – Continue reading