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Archive for International

Italy’s New Flat Tax For First-Time Residents

Marco Rossi

With the Budget Law for fiscal year 2017, Italy enacted a new flat tax for Italian first-time residents. The flat tax amounts to euro 100,000 regardless of the amount of taxable income. Foreign source income is completely exempt from tax, while domestic source income is taxed under the normal rules (graduated tax rates on income brackets generally applying to all resident taxpayers).

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U.S. Expat Taxes For Americans Living In Ireland

Hugo Lesser

It has been estimated that there are several thousand Americans living in Ireland.

Living in Ireland is an incredible experience for a number of reasons, including the friendly locals, the incredible landscapes, the charming culture, not to mention easy access to the rest of Europe. As an American expatriate living in Ireland though, what exactly do you need to know regarding filing U.S. expat (and Irish) taxes?

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Protecting your Company—Asset Control

What controls should be put in place to protect the company’s assets from fraud?

Company assets such as inventory, equipment and vehicles are highly susceptible to fraud and need to be protected. Internal controls should be put in place to protect these assets.

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Tax Treaty Tiebreaker And Reporting: Forms 8938, 8621, 5471

John Richardson

Previously, we have look at the tax treaty tiebreaker and how it relates to taxation of Subpart F and PFIC income as well as eligibility for streamlined offshore procedures. This is another in a series of posts on the tax treaty tiebreaker (which is a standard provision in most U.S. tax treaties).

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Are You Hiding Assets In The BVI?

Ron Marini

The British Virgin Islands’ Government has signed new legislation regarding Beneficial Ownership & Technical Protocol with the UK which will come into force in June 2017, which is hoped to improve the exchange of beneficial ownership information between the UK & BVI law enforcement for taxation rulings.

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Tax Treaty Tiebreaker And Taxation Of Subpart F And PFIC

John Richardson

Before a “Green Card” holder uses the “Treaty Tiebreaker” provision of a U.S. Tax Treaty, he/she must consider what is the effect of using the “Treaty Tiebreaker” on:

A. His/her immigration status under Title 8 (will he/she risk losing the Green Card?)

B. His/her status under Title 26 (will he expatriate himself under Internal Revenue Code S. 7701(b)) and subject himself to the S. 877A “Exit Tax” provisions?

Now, on to the post

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BREXIT Becomes A Disaster For UK With Loss Of Financial Jobs

William Byrnes

Many of the big banks, investment funds, and large insurance companies have announced that hundreds to thousands of employees are being relocated to group members European Union countries. The UK financial industry is on track to lose within two years much more than the previously forecast 75,000 direct high paying financial services jobs and with those will go the back office support and compliance jobs attached.

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Canadian Tax Help – Protecting Your Company: Key Reports

Grant Gilmour, Canada, CPA

What reports should you be reviewing regularly to identify irregularities?

Whether you work in the company daily or manage from afar, there are key reports you should be reviewing regularly to stay informed and detect possible fraud.

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Canada Tax FAQs – What Is A Schedule 91?

Grant Gilmour

What is a schedule 91 as part of a T2 corporate tax return?

Schedule 91 is for non-resident corporations that carried on business in Canada or disposal of taxable Canadian property in Canada that was treaty-protected any time in the year.

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Green Card Holders: Tax Treaty Tiebreaker

John Richardson

Before a green card holder uses the Treaty Tiebreaker provision of a U.S. Tax Treaty, he/she must consider what is the effect of using the Treaty Tiebreaker on:

A. His/her immigration status under Title 8 (will he/she risk losing the Green Card?)

B. His/her status under Title 26 (will he expatriate himself under Internal Revenue Code S. 7701(b)) and subject himself to the S. 877A Exit Tax provisions?

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Italian Supreme Court Ruling On Beneficial Ownership

Marco Rossi

With its ruling n. 27113/2016 issued on December 28, 2016, the Italian Supreme Court interpreted and applied the beneficial ownership provision of article 10 of the tax treaty between Italy and France, for the purpose of determining whether a French holding company, wholly owned by a U.S. corporation, was entitled to the imputed credit granted under that treaty in respect of dividends received from an Italian subsidiary.

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Protecting Your Company: Bank Reconciliations

Grant Gilmour

How does preparing bank reconciliations help to detect and prevent possible fraud?

A bank reconciliation explains the difference between the balance in the bank account per the accounting records and the balance actually in the bank at any given time. The bank reconciliation should be prepared and reviewed monthly to analyze the differences and help detect errors or fraud. This internal control will also help deter fraud.

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