Taxation

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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Taxation

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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Taxation

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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Taxation

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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Taxation

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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Taxation

Roussillon Provence

French Parliamentary legislation has to conform with the Constitution - The law may not be the law...

By Alexane Palide, edited by Prof Robert Anthony, Anthony & Cie

The new French assessment on the effects of the tax reform provided by the project 2018 of the Financial Act highlights the introduction of the new property tax (IFI) based on the old methods. However, the project has been referred to the Constitutional Council for different reasons that we will now analyse.

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Taxation

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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Taxation

Rent of Real Estate in Mexico: Tax Opportunities for US Residents

By José Carreras Benitez, INTEGROUP S.C.

Mexico has been considered a very attractive country for foreign investment. Residents abroad have acquired real estate in Mexico, mainly for relaxing, retirement purposes, and weather conditions. It is very common for US residents to stay in Mexico from October to March of the following year. Sometimes, US residents decide to rent such real estate, which means they are triggering taxable revenues for Mexican purposes.

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Taxation

Load, Aim, Misfire! A look at the practical implications of the additional 3% SDLT rate

By Alex Barnes, Memery Crystal LLP

It’s almost a year now since the Government in the UK introduced the additional 3% Stamp Duty Land Tax (SDLT) rate on certain purchases of dwellings. This was no doubt done partially to raise revenue, but in the main was probably to appeal to voters by once again targeting those ‘nasty wealthy landlords’. As is often the case with new or additional taxes, this tax hike is prone to misfire and in many cases it’s not those that the Government was probably seeking to target who actually bear the brunt of the change.

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