TaxConnections


 

Tag Archive for International Tax

Mamma Mia! Italian Tax Court Rules On Inter-Company Loan Interest Withholding Tax, Beneficial Owner Withholding Exemption

Marco Rossi, Tax Advisor

With its Ruling n. 4091 of June 12, 2017, the Eighth Department of Tax Commission (District Tax Court) of Milan, Italy ruled that upon the cancellation of an inter company loan from a Dutch parent company to its Italian subsidiary, the interest accrued on the loan and deducted by the Italian subsidiary on an accrual basis, during the course of the loan, is deemed “constructively received” by the foreign parent, and is potentially subject to the Italian interest withholding tax (at the rate of 20 percent, pursuant to article 26, paragraph 5 of Presidential Decree n. 600 of 1973, recently increased to 26 percent).

However, the Tax Court also ruled that the Dutch parent company qualified as “beneficial owner” of the interest, and was eligible for the withholding tax exemption granted under article 26-quater of Presidential Decree n. 600 of 1973, which implemented the EU Directive n. 2003/49/CE (so called interest and royalties directive).

Read more

FATCA’S Unintended Consequences – Feeding Corruption And Suppression Of Political Rivals

William Byrnes, Tax Advisor

FATCA’s primary purpose was for the U.S. government to obtain otherwise private financial information and exercise control of the global financial industry. Unlike a conventional withholding tax which actually intends to collect tax, FATCA imposes penalties based upon non-compliance with tax.

The tax revenue projections, which were used to validate the passage of FATCA did not show FATCA raising any significant tax revenue annually. In fact, except for the extraordinary penalties assessed, little additional tax has been collected. In comparison to the annual on budget spending by the U.S. government, the actual amount of tax collected by FATCA is statistically insignificant.

Read more

American Expatriates In London – Tax Info You Need

Hugo Lesser

American expats living in London find themselves in the unenviable position of having to file both U.S. taxes as a U.S. citizen, and UK taxes as a UK resident, on their worldwide income.American expats living in London find themselves in the unenviable position of having to file both U.S. taxes as a U.S. citizen, and UK taxes as a UK resident, on their worldwide income.

To complicate things further, the UK tax year runs from April 6th to April 5th, rather than being the calendar year. Read more

Canadian Tax FAQs – What Is A Trust Audit?

What is a Trust Audit?

Some professionals such as Real Estate Agents and Lawyers keep trust accounts (funds held on behalf of their clients). There are special accounting rules for these trust accounts and a Trust Audit is designed to ensure compliance with these accounting rules. Read more

PFIC And Canadian Mutual Funds

Why are PFIC rules important for holders of Canadian mutual fund?

Many American citizens living or working in Canada have invested in Canadian mutual funds – likewise, many Canadians who subsequently moved to the United States retained their Canadian mutual funds holdings. They likely are unaware of the PFIC rules. Consequently many American taxpayers holding Canadian PFIC have not met their reporting obligations. Not only that  but PFIC investments are to be avoided since its taxation (with the exception of the QEF regime) is designed to be punitive. Read more

Hale Stewart Webinar – U.S. International Tax – Today!

It has never been easier for a U.S. company to sell products or services internationally. But once a company earns international income, it also must content with internal tax consequences. This is made more complicated because of the myriad number of tax statutes implicated by international sales.

Read more

Hale Stewart Webinar – U.S. International Tax – This Friday!

It has never been easier for a U.S. company to sell products or services internationally. But once a company earns international income, it also must content with internal tax consequences. This is made more complicated because of the myriad number of tax statutes implicated by international sales.

Read more

Webinar – U.S. International Tax – Friday June 2nd

It has never been easier for a U.S. company to sell products or services internationally. But once a company earns international income, it also must content with internal tax consequences. This is made more complicated because of the myriad number of tax statutes implicated by international sales.

Read more

Intro to U.S. International Tax – Webinar June 2, 2017

It has never been easier for a U.S. company to sell products or services internationally. But once a company earns international income, it also must content with internal tax consequences. This is made more complicated because of the myriad number of tax statutes implicated by international sales.

Read more

Great Feedback On Hale Stewart’s Webinars

The content of the webinars presented on www.taxconnections.com is important! We just received a very nice message from Rajendra Singh who attended the “Captive Insurance For CPAs” taught by Hale Stewart last week: “I enjoyed your webinar yesterday. You will make one of the best-liked teachers on any campus. I bought your book on Captives.”

Read more

Introduction to International Tax Webinar – Tomorrow, May 3rd

Hale Stewart

It has never been easier for a U.S. company to sell products or services internationally. But once a company earns international income, it also must content with internal tax consequences. This is made more complicated because of the myriad number of tax statutes implicated by international sales. An Introduction to U.S. International Taxation offers the CPA introduction to the basic rules and structures used in international transactions. The program is broken down into the following sections:

Read more

Webinar – Intro To International Tax – May 3

Hale Stewart

It has never been easier for a U.S. company to sell products or services internationally. But once a company earns international income, it also must content with internal tax consequences. This is made more complicated because of the myriad number of tax statutes implicated by international sales. An Introduction to U.S. International Taxation offers the CPA introduction to the basic rules and structures used in international transactions. The program is broken down into the following sections:

Read more

TaxConnections