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.
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.
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.
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.
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.
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.
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.
By Sérgio Ramos, Pontes, Baptista & Associados
What is a Non-Habitual Resident (NHR)? One of the principal objectives of this regime was to attract individuals and their families to Portugal by making it beneficial from a tax perspective to become tax resident in Portugal. The NHR regime provides a flat income tax rate of 20% for certain Portuguese employment and self-employment sourced income.
By Graeme Saggers, Nolands SA
South Africa has concluded a treaty with the United Arab Emirates (UAE) which was effective from the 1st of January 2017. This treaty is largely based on the OECD Model Tax Convention; some of the defining features of the treaty are as follows.
By José Alves do Carmo and Tânia Sofia Rosário, AVM Advogados
Sun, sea, reduced cost of living, safety, but mainly a lower tax burden. Portugal has long since ceased to be just a country at the tail of Europe. Its potential is known globally, being one of the most sought countries for investing and establishing residence. Approved in 2009, the Tax Regime for Non-Regular Residents (NRR) is yet another step towards international tax competitiveness.
