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IRS Announces New Relief Procedures for Expatriates

By Laurie B. Kazenoff, Moritt Hock & Hamroff LLP

In September 2019, the IRS announced procedures for certain persons who have relinquished, or intend to relinquish, their US citizenship and who wish to come into compliance with US income tax and reporting obligations and avoid being taxed as a “covered expatriate” under section 877A of the US Internal Revenue Code.

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Data Protection

Alternative Methods for Retrieving Taxpayer Information from the IRS

By Laurie B. Kazenoff, Moritt Hock & Hamroff LLP

In its ongoing effort to protect taxpayers from identity theft, the US Internal Revenue Service announced it will stop its tax transcript faxing service on 28 June 2019 and will amend the Form 4506 series (tax return copy requests) to end third-party mailing of tax returns and transcripts in July.

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Living and working in Hannover

Main Tax Residency Rules in Germany for Employees: An Overview

By Ulrich Gehrke and Vanessa Szymik, Gehrke econ Group

Individuals with a domicile for private use or a customary place of abode in Germany are considered to be residents in Germany. A customary place of abode in Germany is fulfilled if an individual intends to stay a continuous period of six months or more in Germany, considering that this period may be split across two calendar years. The status of being a German resident leads to an unlimited taxation of individual’s worldwide income.

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Before the Devil Knows You’re Dead? Renunciation of U.S. Citizenship as an Estate Planning Tool

By Alexander Marino JD, LLM (US Tax) and Kevin Kirkpatrick JD, MBA, Moodys Gartner Tax Law LLP

Oscar Wilde’s characters remarked in several of the playwright’s works that “when good Americans die they go to Paris.” Wilde also made observations about taxes, but he probably was not aware that even the supposedly good Americans who make it to the City of Light are followed there—during life and after death—by the IRS.

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Amsterdam

Update on Dutch withholding taxes

By Edward Hendrickx, EJP Accountants & Adviseurs

Did you know that U2 is not an Irish band but a Dutch one? And that the Rolling Stones are from Amsterdam? Although the managers of these bands deny it, it is often assumed that their main offces are established in the Netherlands due to the lack of royalty withholding taxes. This might change.

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Pre-Immigration Planning Considerations for Nonresident Aliens

By Patrick J. McCormick, Drucker & Scaccetti, P.C.

For a multitude of reasons, some foreign individuals of significant wealth will desire to establish domicile in the United States – either through citizenship or otherwise establishing a long-term presence in the country. One major drawback is the tax ramifications associated with such United States presence.

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Bitcoins

Tax treatment of cryptocurrencies such as Bitcoins in Germany

By Oliver Biernat, Benefitax GmbH

The rapid rise in the price of bitcoin and other crypto currencies has attracted a great deal of media attention. The blockchain technology is regarded by many as trend-setting. In recent years, an increasing number of people have traded, exchanged or paid with cryptocurrencies. Mining blocks is not only carried out by large investors but also by IT-affne private individuals. This raises several questions. On the one hand, the question of whether a trading or private activity exists and, on the other hand, whether and, if so, how profits and sales are taxed.

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Fund Managers’ Carried Interests will be Taxed at 26% in Italy

By Prof Stefano Loconte and Angela Cordasco, Loconte & Partners

In order to make Italy more attractive for relocating private equity partners, Decree n. 50 of 24 April 2017 has officially approved the new withholding tax rate for their carried interests. The new regulation is very favorable, considering the current European scenario after Brexit, since many equity partners must decide in which EU member state they should establish their company’s headquarters and whether to keep their EU passports.

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The Trust Instrument and the New Res-Non-Dom Italian Regime

By Prof Stefano Loconte and Francesca Paulon, Loconte & Partners

We would like to say a few words about two of the biggest revolutionary fiscal developments Italy is experiencing: the new Italian ‘res-non-dom’ regime and the less new (but currently in the status of being reformed) trust instrument.

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