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FOREIGN Investors in US Real Property: FIRPTA WITHHOLDING CERTIFICATE

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We have previously wrote on FIRPTA here -  http://www.mooresrowland.tax/2015/12/firpta-update.html
If the amount of the FIRPTA withholding tax (generally 15% of the selling price) will exceed your  “maximum US tax liability”, we can apply to the IRS for a withholding certificate to reduce, or waive, the withholding, down to the maximum US tax liability.

If the application is filed by the day of closing, the closing agent will retain the FIRPTA withholding tax in escrow until the IRS response (the withholding certificate) is received. When the certificate is received, the tax withheld is refunded by the closing agent, in accordance with the instructions in the certificate - i.e most, or all, of the FIRPTA withholding tax is refunded. This process can be completed in about 3 months. Otherwise, under normal procedures, and current IRS restrictions, you could wait a year, or longer, to receive the refund.


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Withholding Certificates

The amount that must be withheld from the …

Let's Talk About Tax Treaties

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In addition to the U.S. and foreign statutory rules for the taxation of foreign income of U.S. persons and U.S. income of foreign persons, bilateral income tax treaties limit the amount of income tax that may be imposed by one treaty partner on residents of the other treaty partner. Treaties also contain provisions governing the creditability of taxes imposed by the treaty country in which income was earned in computing the amount of tax owed to the other country by its residents with respect to such income. Treaties further provide procedures under which inconsistent positions taken by the treaty countries with respect to a single item of income or deduction may be mutually resolved by the two countries.

The preferred tax treaty policies of the United States have been expressed from time to time in model treaties and agreements. The Organization for Economic Cooperation and Development (the “OECD”) also has published model tax treaties. In addition, the United Nations has published a …

Moving from Singapore....to the UK?

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The exodus from Singapore continues. I'm told that expats trying to ship household goods are facing delays.  It's August and no containers are available until February next year?

The destinations of choice have to be Europe and New Zealand.  Even Americans seem to prefer Europe to going back to the States.

I was in the UK for a month myself and only just left yesterday.  For those moving to the UK in September or October this year, there are of course questions around the tax implications of the move.

As always, the answer is that...it depends

1. You may be able to choose whether you are to be taxed either on the remittance basis or on the arising basis -
Read more here - http://www.mooresrowland.tax/2018/03/uk-tax-arising-vs-remittance-basis.html

2. You should also need to determine whether you meet the statutory residence test or not.  There's a detailed discussion below but here's a tool from the HMRC website -
https://www.gov.uk/government/uploads/system/uploads/at…