TaxConnections


 

Archive for International

Rental Expenses Ireland – High Court Decision

Claire McNamara

The High Court decision in Revenue Commissioners v Thomas Collins has just been published.

It states that contrary to Revenue’s position, the NPPR (Non Principal Private Residence) charge was in fact an “allowable” expense against rental profits under Section 97(2) TCA 1997.

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Accounts Payable On A Balance Sheet – Canada Tax

What are Accounts Payable on a Balance Sheet?

The Accounts Payable category appears under Current Liabilities on a Balance Sheet, as it is expected that these amounts owing will be paid within one year. It represents funds that a company has an obligation to pay vendors or creditors for goods and services received.

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Corporate Tax Payment & Filing – Ireland

Clare McNamara

Corporation Tax Returns

The Irish corporation tax system operates on a self-assessment basis. Therefore, it is solely the responsibility of the company to calculate and pay its corporation tax liability within deadline.

Any company liable to corporation tax must submit a CT1 Form which is a Tax Return containing details of profits, chargeable gains and other relevant information as outlined in Section 884 TCA 1997.

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Corporation Tax Residence And Registration – Ireland

Claire McNamara

Registration

If you intend to set up a new company in Ireland in 2017, please be aware that you must register with the Irish Revenue Authorities within thirty days of incorporation. This can be done by completing the relevant sections of a TR2 Form:

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DoJ Reaches Final Resolutions Under Swiss Bank Program

William Byrnes

The Department of Justice announced today that it has reached final resolutions with banks that have met the requirements of the Swiss Bank Program. The Program provided a path for Swiss banks to resolve potential criminal liabilities in the United States, and to cooperate in the Department’s ongoing investigations of the use of foreign bank accounts to commit tax evasion. The Program also provided a path for those Swiss banks that were not engaged in wrongful acts but nonetheless wanted a resolution of their status. Banks already under criminal investigation related to their Swiss-banking activities and all individuals were expressly excluded from the Program.

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Argentina Signs Information-Sharing Agreement With The U.S.

Ron Marini

The agreement, in which Argentine officials said they were pursuing in September, is part of a government crackdown on alleged tax evasion by individuals. Argentina also has implemented a tax amnesty plan to recover an estimated $500 million in assets held abroad.

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Monaco Strengthens International Tax Co-operation

William Byrnes

Monaco today deposited its instrument of ratification for the Convention on Mutual Administrative Assistance in Tax Matters (“the Convention”). By doing so, Monaco underlines its commitment to fighting tax evasion and avoidance and takes another important step in implementing the Standard for Automatic Exchange of Financial Account Information in Tax Matters developed by the OECD and G20 countries as well as automatic exchange of Country-by-Country Reports under the OECD/G20 Base Erosion and Profit Shifting (BEPS) Project.

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Tax Residency In Canada: Deemed VS. Factual Resident

John Richardson

Tax Residency is becoming an increasingly important topic. Every country has its own rules for determining who is and who is not a “tax resident” of that country. The advent of the OCED CRS (“Common Reporting Standard”) has made the determination of “tax residence” increasingly important.

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Court of Appeals Reverses Santander’s Foreign Tax Refund

Ron Marini

The First Circuit Court of Appeals overturned an earlier $234 million victory for Santander Holdings USA Inc. after ruling on December 16, 2016 that an internal securities transaction the bank had engaged in lacked economic substance and does not qualify for foreign tax credits.

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Tax Residency VS Physical Presence: 4 Questions You Must Ask

John Richardson

An introduction to “tax residency.”

Most people equate residency with physical presence. The thinking is that “your residence is where you live”. There is no necessary correlation between where one lives and where one is a “tax resident”. Residence for tax purposes may be only minimally related to residency for immigration purposes. It is possible for people to live in only one country and be a tax resident of multiple countries. The most obvious example is “U.S. citizens residing outside the United States”.

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Canadian FAQ – Shareholders’ Equity – What You Need To Know!

Grant Gilmour

What is Shareholders’ Equity? Shareholders’ Equity is often used to measure the net worth of a company. It is used to assess the financial strength of a company.

Discussion:

Shareholders’ Equity (also commonly referred to as Owners’ Equity) comes from two sources:

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“Accidental Americans” Caught In A Kafkaean Trap

Kat Jennings

This article was passed along to us and was originally printed in French for the French magazine L’obs. Due to its dealings with FATCA, we decided to post it for you.

A recent US tax law requires all nationals to report their income. Those who were born by chance in the United States like Fabien live a nightmare.

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