INTRODUCTION HMRC have successfully challenged the offshore residence of Jersey companies holding UK real estate. In the case of Development Securities, the First Tier Tribunal held that Jersey companies set up to hold UK real estate were resident in the UK for tax purposes. This case serves as a timely… – Continue reading
Tax returns and annual financial disclosures contain different information Candidates and members of Congress are required by law to file personal financial disclosures that are designed to shed a light on their potential conflicts of interest. These documents show a lawmakers’ assets and liabilities, reported in broad ranges. Tax returns,… – Continue reading
The Canada Revenue Agency (CRA) has said that audits it undertook between April 2015 and March 2017 of real estate transactions resulted in more than CAD329.4m (USD249.2m) in assessed income that had not been reported. The CRA said that, during this period, it completed over 21,000 audit files related to… – Continue reading
In Federal Budget 2017, the Government is clamping down on tax avoidance by foreign investors in real estate, by tightening the foreign resident capital gains tax withholding regime. The new laws apply to both Australian resident and foreign resident vendors: Australian resident vendors of real property of $750,000 or more… – Continue reading
Transferring wealth to a spouse who isn’t a U.S. citizen can create complex gift, estate and generation-skipping transfer tax challenges. Such transfer tax issues require careful planning, as well as a clear understanding of the differences in how citizens and non-citizens are taxed. Unlike citizens and resident aliens, a non-resident… – Continue reading
Apartment construction is booming as the wealthy rush to invest in rental housing as a way to reduce inheritance tax and banks hand out easy mortgages, but concerns are mounting that excessive supply paired with a shrinking population could soon lead to the bursting of the bubble. New starts on… – Continue reading
The United States continues to be a magnet for immigration, with nearly 8 million new immigrants settling here between 2008 to 2014 — and some of these new immigrants are high-net-worth individuals who are unprepared for the intricacies of the U.S. tax law, according to Seth Entin, a shareholder at… – Continue reading
Overview of the Tax As expected, the Government of Ontario has introduced a new non-resident speculation tax (“NRST”) that takes effect on April 21, 2017. The NRST is a 15% tax payable on the purchase of an interest in residential property located in the “Greater Golden Horseshoe” area (which includes… – Continue reading
The Canada Revenue Agency (CRA) will dedicate resources to ensuring that the real estate sector in the Greater Toronto Area (GTA) complies with the tax laws. The commitment of CRA resources was one of the outcomes of a meeting between the federal and Ontarian finance ministers and the Toronto Mayor… – Continue reading
The federal government is considering doubling the tax rate applied to more than $199 billion worth of so-called stapled structures, in a move that experts say could scare off foreign investors. Separate securities, such as a share in a company and a unit in a trust, can be stapled together… – Continue reading
Property buyers will be quizzed about their tax residency under new anti-money-laundering rules being introduced by Westpac and its subsidiaries St George Bank, Bank of Melbourne and BankSA. Mortgage brokers, who act as intermediaries between the banks and buyers, are being told that from this week they must also ask… – Continue reading
Beware of the dreaded inheritance tax and changes to it from April 2017! Approximately 1.3 million Britons now live in Australia and Brexit may only increase this number! Many think that moving to Australia means they no longer need to worry about UK tax, but often they are not fully… – Continue reading
A section of the president’s 2005 tax return revealed that about 85% of what he paid the IRS was incurred due to ‘alternative minimum tax’ Donald Trump’s leaked tax return reveals that the businessman had to pay tens of millions of dollars in a single year because of a tax… – Continue reading
The new Residence Nil Rate Band will allow people to pass on property to their descendants tax free. But some people need to take action now or risk missing out. In April, a major change to inheritance tax (IHT) law comes into effect with the launch of the Residence Nil… – Continue reading
The European Parliament’s Monetary Affairs and Civil Liberties committees’ overwhelming support for access by EU citizens to information concerning the beneficial owners of companies without having to demonstrate a ‘legitimate interest’ and trusts would have to meet the same requirements. MEPs agreed the on their position on EU Anti-Money Laundering… – Continue reading
MPs propose tweaks to the Union Revenue Bill. The solution to widespread tax evasion on land purchases is the creation of a fairer, more even taxation system. This was the prevailing opinion of MPs assembled in Nay Pyi Taw last week to deliberate the Union Revenue Bill prescribing three tax… – Continue reading
On October 3, 2016 the Federal Government proposed changes to the Income Tax Act (the “Act”) and administrative policies that will impact claiming the principal residence exemption. 1. All dispositions of principal residences must now be reported. Previously, the CRA did not require taxpayers to report the sale of a… – Continue reading
ISLAMABAD – The Securities and Exchange Commission of Pakistan (SECP) has proposed the government to give one time amnesty scheme for the owners of offshore companies to declare their hidden assets by paying nominal tax. “I have asked the Finance Minister Ishaq Dar to give one opportunity to offshore companies… – Continue reading
The OECD recently released a public discussion draft entitled the “BEPS Action 6 Discussion Draft on non-CIV examples” to clarify when investors like private equity funds, real estate funds and hedge funds should be entitled to tax treaty benefits. The release of the 2017 Discussion Draft is timely, given that… – Continue reading
On December 21, 2016, the new Canada–Israel tax treaty entered into force. The new treaty was signed on September 21, 2016 in New York, and replaces the existing treaty that dates from 1975. For most purposes, the provisions of the new treaty took effect as of January 1, 2017. Overall,… – Continue reading
KARACHI: Finance minister Ishaq Dar on Friday said that tax evaders will find no place to park their ill-gotten money, as Pakistan will begin automatic-exchange of information from next year. “As per international agreement with OECD (Organisation of Economic Cooperation and Development), Pakistan will start automatic exchange of information regarding… – Continue reading
Portuguese income tax law provides for a 20% reduced rate and, in respect to income obtained abroad, a full tax exemption, for certain types of income derived by individuals having the status of Non-Habitual Portuguese Residents (NHPR). Any individual that in a certain year becomes tax resident in Portugal will… – Continue reading
The 2017 Budget Law introduced (starting from fiscal year 2017) favourable provisions for people wishing to become tax residents in Italy. It is aimed at wealthy individuals who wish to bring in new capital resources. The regime is inspired by the non-domiciled resident regime which is in force in the… – Continue reading
The Slovak Government and Parliament made several changes to the tax system with effect from 1 January 2017. The recently adopted amendments concern – among others – corporate and personal income tax, value added tax, special levy in regulated industries, as well as social security and health insurance contributions. Here… – Continue reading
According to unofficial estimates, more than $2 billion has flowed into Dubai real estate from Pakistanis every year for the past three years. Last week, account holders in a major UAE bank began receiving letters alerting them that soon they would be required to furnish information “with a view to… – Continue reading
General On 30 November 2016, Kazakhstan adopted certain amendments to its Tax Code (the Tax Amendments). Most of the Tax Amendments take effect on 1 January 2017. Below we summarize some of the most important Tax Amendments: VAT Registration Threshold Under the Tax Amendments, the existing VAT registration threshold (i.e.,… – Continue reading
MUMBAI, India — In one of the most audacious experiments in India’s modern history, Prime Minister Narendra Modi banned the two largest bills — of 500 rupees, or about $7.50, and 1,000 rupees — which account for about 86 percent of the currency in a country where 78 percent of… – Continue reading
New tax takes effect on Jan. 1; highest penalties could reach C$10,000 a day Vancouver is implementing a new tax policy to rein in an overheated real estate market by forcing absentee landlords to make their vacant homes available for lease. Starting Jan. 1, the Empty Home Tax will be… – Continue reading
Department of Finance receives ‘unprecedented’ lobbying from property funds Overseas investors in Irish property may have to wait for a further two months for clarity on how the Government plans to tax structures they have used to snap up billions of euro of real estate after the financial crisis. The… – Continue reading
The Indian government has sent out about 700,000 notices to suspected tax evaders to coax them to declare hidden income and assets, promising they won’t be pursued by the authorities if they pay a penalty now to clear their name. But, as the four-month campaign draws to a close this… – Continue reading
New Zealand will extend its anti-money laundering laws to cover real estate agents and other professions amid fears the country has become a soft target for illegal fund flows that have also helped inflate the property market. Soaring property prices have become a hot issue among the New Zealand public… – Continue reading
Gov’t sends bill to Congress to force banks to share account data automatically Described by government officials as a “lethal blow” to bank secrecy, Uruguay has sent a bill to Congress that will force banks to automatically provide the DGI tax bureau information on the accounts held by individuals and… – Continue reading
Last Wednesday August 10 at Germany’s Federal Foreign Ministry Office, Costa Rica and Germany celebrated the ratification of the establishment of legal instruments as part of an agreement to eliminate double taxation of income and assets, stated Costa Rica’s Ministry of Foreign Relations in a press release Friday. The agreement… – Continue reading
The government is hell-bent on cracking down on black money and undisclosed income of Indians within the country and safely stowed away abroad. While there is no proper estimation of the actual amount of black money in the economy, the government is actively taking measures to stop it. Recent media… – Continue reading
The Malaysian government won’t protect its citizens from legal action taken outside the country stemming from the scandal surrounding the state investment fund 1 Malaysia Development Berhad, a senior official said this week. Johari Abdul Ghani, who is second in command in the Finance Ministry under Prime Minister Najib Razak,… – Continue reading
The political, economic and constitutional fallout of the UK’s referendum decision to leave the European Union (Brexit) will continue for some time. In addition to considering some of the possible domestic UK tax implications of Brexit, this OnPoint also considers some of the potential tax implications from the perspective of… – Continue reading
A new double tax treaty between France and Singapore will be of particular help to French companies operating in Singapore, especially in the construction industry, an expert has said. Franck Lagorce, an expert in French tax at Pinsent Masons, the law firm behind Out-law.com was commenting following an announcement from… – Continue reading
The Delhi HC has delivered path-breaking and bold verdicts, quashing proceedings initiated by CBDT and CBEC administrative guidance for assessments and subsequent denial of benefits. A question tax professionals are often asked is: Has the government done enough to address the situation on tax? Several negative catchphrases had peppered headlines… – Continue reading
Dubai: UAE-based multinationals will start to feel the impact of the OECD Base Erosion and Profit Shifting (BEPS) proposals that come into effect this year, a KPMG seminar on international tax developments has revealed. The BEPS proposals are focused on mitigating tax planning strategies that exploit gaps and mismatches in… – Continue reading
With regard to the increasing talk in the US Congress on tax reform, American Citizens Abroad (ACA) has provided the House of Representatives Ways and Means Committee with a full reform proposal for the enactment of residence-based taxation (RBT) for American expatriates. ACA has said lawmakers should enact RBT instead… – Continue reading
Minutes after midnight on Saturday, Chen Sheng, a businessman from the southern city of Wenzhou, got a value-added tax (VAT) invoice after paying his bill at a hotel in Beijing. To his surprise, the invoice was the very first issued in China after the country replaced all business tax with… – Continue reading
Greek banks and the state are in the process of creating a national register for offshore company owners, in compliance with a European Union directive to that effect. The register will be created on the Teiresias databank, known from its list of insolvent borrowers. Access will be granted to the… – Continue reading
History shows us that tax evasion can have terrible effects, from economic inequality to societal collapse. In a world seemingly inured to financial scandals, the Panama Papers leak has reminded us of their capacity to shock. This huge document dump, which has revealed thousands of offshore accounts held in the… – Continue reading
The Swiss-run humanitarian organisation International Committee of the Red Cross (ICRC) has allegedly been used without its knowledge to mask the true beneficiaries of offshore accounts whose details were leaked in the Panama Papers. According to revelations by the Swiss papers Le Matin Dimanche and SonntagsZeitung on Sunday, the ICRC… – Continue reading
Premier Li Keqiang’s message to the country’s tax and financial authorities is crystal clear: The ongoing landmark tax reform must reduce burdens on all industries. One month before the May 1 deadline of a sweeping reform that seeks to replace China’s decadeslong business tax with a value-added tax, Li visited… – Continue reading
The government is cutting the tax on real estate investment trusts (REITs) to boost local use of the financial mechanism that employs commercial properties like malls, hospitals, warehouses, hotels and office buildings as underlying assets. Indonesia only had two REITs created in the country in the past nine years, namely… – Continue reading
Pune: The property tax department of Pune Municipal Corporation has sealed 14 properties after their owners defaulted on tax payment in the last three days. The administration took action against the owners of these properties because they had refused to pay the pending tax amount worth around Rs 70 lakh…. – Continue reading
The first Budget tabled by Canada’s new Liberal Government provides for a major crackdown on tax evasion and avoidance, and streamlines the domestic tax credits system. The Budget was delivered by Finance Minister Bill Morneau on March 22, 2016. He told Parliament: “Today, we begin to restore hope for the… – Continue reading
New Delhi: A new report on Indians stashing their black money in tax haven and assets abroad illegally is startling. As per a report in the Times of India, senior economists from the Bank of Italy have come up with an estimate on black money. The report states that Indians… – Continue reading
The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast. VIRGINIA CORPORATE INCOME TAX Conformity with Internal Revenue Code. Virginia Governor Terry McAuliffe signed emergency legislation on February 5, 2016 that advances the state’s… – Continue reading
