Kassel, Germany

Exit tax in Germany

By Bernhard Schwechel, FACT GmbH

Effective 01 January 2022, Germany has revised the exit taxation rules for privately held company shares. In particular, interest-free, indefinite deferral – in the case of a relocation of EU/EEA citizens within the EU/EEA area – is abolished and replaced by the possibility of a seven-year instalment payment.

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The High Court has decided: no discrimination for working holiday makers

By Tony Nunes, Kelly + Partners Chartered Accountants

The High Court of Australia’s decision in Addy’s case in late 2021 is a landmark decision favouring working holiday makers (WHMs) in Australia. This recent decision by the High Court provides assurance to working UK holidays makers (and others) that they will be subject to the same concessional tax rates that Australian nationals enjoy.

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Basic US Tax Considerations in Investing in US Real Estate

By Robert M. Finkel, Moritt Hock & Hamroff LLP

Whether your investment in US real estate is intended for personal use – that is, the property will be used by you and your family exclusively as a personal residence (perhaps also made available on occasion to friends and extended family gratis); investment use – that is, held as an investment property, rented to unrelated third parties; or for both personal and investment use, you will want to be aware that its ownership could subject you to US tax.

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Calgary, Canada

CRA Taking Inspiration from the IRS: New Form T1134

By Kenneth Keung and Aasim Hirji, Moodys Private Client Law LLP

Canadian taxpayers and their advisors should be aware of stringent new T1134 reporting requirements if they own interests in any corporations outside of Canada. A “reporting entity” (being a Canadian resident individual/ corporation/trust, or a partnership in which Canadians own collectively more than 10% or that owns interests in a “foreign affliate”) is required to file T1134 forms annually. Generally, a “foreign affliate” is a non-Canadian corporation in which the Canadian, along with related persons, owns 10% or more of any class of shares.

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Australian property

Investing in Australian Property

By Peter Cohilj, Kelly + Partners Chartered Accountants

In this article we provide an overview of some of the property holding structures and state property taxes that should be considered prior to investing in Australian property.

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Changes to withholding tax applied to income from gainful activity in Switzerland

By Andreas Hänggi, Treuhand- und Revisionsgesellschaft Mattig-Suter & Partner

The overhaul of withholding tax has established the necessary prerequisites for ending the differences between the treatment of taxpayers who are subject to withholding tax and those who are subject to ordinary taxation, as well as enabling Switzerland to comply with its international obligations. These changes came into force on 01 January 2021.

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Frankfurt, Germany

10 Tax Tips You Should be Aware of Before Relocating to Germany

By Oliver Biernat, Benefitax GmbH

Many people wish to live in Germany because of its beautiful landscape, clear air and economic success but few think about the tax consequences. Germany is not a low-tax jurisdiction and has many anti-tax-avoidance rules. It is therefore extremely important for people with high incomes or wealth to have a German tax expert review their tax situation before moving to Germany, especially in these cases:

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Philadelphia, USA

IRC Section 965 Transition Tax Audits: Don’t Be Caught Off-Guard

By Ronald Kalungi, Drucker & Scaccetti, P.C.

The Tax Cuts and Jobs Act (TCJA) of 2017 amended section 965 of the Internal Revenue Code (IRC) by imposing a one-time tax on US persons owning stock in certain foreign corporations with untaxed earnings as of the date the TCJA came into force. At the time of its enactment, this transition tax was estimated by Congress’s Joint Committee on Taxation to raise USD 338.8 billion in tax revenue during the fiscal years 2018 through 2027. The revenue yield from this tax has actually been much lower than expected. The Tax Inspector General for Tax Administration (TIGTA) reported that as of 08 November 2018, taxpayers had reported only USD 30.2 billion in section 965 tax and paid only USD 11.2 billion (deferring USD 22.7 billion). This poor revenue yield has made the transition tax one of the principal focal areas of audit compliance efforts by the Internal Revenue Service (IRS) – efforts that shouldn’t catch affected taxpayers off guard.

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Chicago, USA

Relief Procedures for Certain Former US Citizens

By Howard Bakrins, Kutchins, Robbins & Diamond

On 06 September 2019, the IRS released its Relief Procedures for Certain Former Citizens and frequently asked questions (FAQs) (available at www.irs.gov/individuals/ international-taxpayers/reliefprocedures- for-certain-formercitizens), which allow certain persons who have relinquished, or intend to relinquish their US citizenship (expatriation), to comply with their US income tax and reporting obligations without having to remit any unpaid taxes and penalties.

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