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Showing posts from 2016

Potential UK Non Dom Changes

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Understand more Draft legislation was published on 5 December 2016 giving further details of the UK government’s proposed changes to the taxation of non-domiciles.
The rules are still in draft and so subject to comment and adjustment but likely to receive Royal Assent in the Summer of 2017 but taking effect from 6 April 2017.
After an eighteen month period of consultation the new certainty for non-doms is welcome. It is clear that the government will now make key changes to the taxation of non-domiciles (“non-doms”).
The changes will affect all non-doms both in their personal capacity, and especially those who are settlors or beneficiaries of offshore structures. They will also affect overseas trustees and non-doms (resident and non resident) owning residential property in the UK.
The Finance Bill also reflects the government’s clear wish to stimulate investment in the UK. It is not all about increasing the tax take from non-doms. The draft legislation offers two main avenues for non…

Singapore: Implementation of the Common Reporting Standard (“CRS”) with effect from 1 January 2017

Date: 30 December 2016


Dear Sir/Madam,

The Income Tax (International Tax Compliance Agreements) (Common Reporting Standard) Regulations 2016 (“CRS Regulations”) will come into effect on 1 January 2017.

The CRS is an internationally agreed standard for the automatic exchange of financial account information (“AEOI”), endorsed by the OECD and the Global Forum for Transparency and Exchange of Information for Tax Purposes, to deter and detect tax evasion through the use of offshore bank accounts. More than 100 jurisdictions, including major financial centres such as Hong Kong, Luxembourg and Switzerland, have endorsed the CRS and will commence AEOI in either 2017 or 2018.

The CRS Regulations empower and require all financial institutions (“FIs”) to put in place necessary processes and systems to obtain CRS information from account holders (known as the “Wider Approach”) that open a new account with the FIs from 1 January 2017.  FIs will have to establish the tax residency status of all their …

What is the potential impact of President Trump?

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New ITIN Acceptance Agent Program Changes

The IRS has updated procedures that affect the Individual Taxpayer Identification Number (ITIN) application process. Taxpayers and their representatives should review these changes identified below before requesting an ITIN: Certification Process Changes (2016)CAAs will now be allowed to authenticate the passport and birth certificate for dependents. CAAs will continue to certify identification documents for the primary and secondary applicants. Form W-7 (COA), Certificate of Accuracy for IRS Individual Identification Taxpayer Number, must be attached to each Form W-7 application submitted as verification they have reviewed the original documentation or certified copies from the agency that issued them. CAAs will have to attach and send copies of all documentation reviewed with the Form W-7 COA to the IRS.

As a reminder, AAs and CAAs must conduct an in person interview with each applicant (primary, secondary and dependent) in order to complete the application.  Video conferencing (i.e.…

Making Tax Payments to HMRC

1.Bank details for online or telephone banking, CHAPS, Bacs You can make a transfer from your bank account by Faster Payments, CHAPS or Bacs. Your bill will tell you which account to pay in to. If you don’t have a bill, or you’re not sure, use HMRC Cumbernauld. Account details to use Sort code Account number Account name 08 32 10 12001039 HMRC Cumbernauld 08 32 10 12001020 HMRC Shipley If your account is overseas Bank identifier code (BIC) Account number (IBAN) Account name BARCGB22 GB62BARC20114770297690 HMRC Cumbernauld BARCGB22 GB03BARC20114783977692 HMRC Shipley

2. By cheque through the post

You can send a cheque by post to HM Revenue and Customs (HMRC).HMRC
Direct
BX5 5BD You don’t need to include a street name, city name or PO box with this address. If you have a reply envelope showing a different address (HMRC, Bradford BD98 1YY), you can still use the envelope to post your cheque. Allow 3 working days for your payment to reach HMRC. What to includeMake your cheque payable to ‘HM Revenue and Customs only’ f…

Considerations for a Foreign Irrevocable Trust / Foreign Non-Grantor Trust holding US Real Estate

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BEA - Acquisition and Ownership
Currently, the U.S. does not tax, or impose a filing obligation on, the acquisition or mere ownership of U.S. real property by a foreign person. The U.S. Department of Commerce’s Bureau of Economic Analysis (BEA), however, requires that certain surveys be completed by foreign persons who own substantial holdings of U.S. real property. These surveys are issued and collected by the BEA for purposes of gathering statistical data on foreign investment in the United States and can be summarized generally as follows: quarterly reporting of certain positions and transactions concerning the U.S. real property and its foreign owner(s), and foreign affiliates of its foreign owner(s), on the Quarterly Survey of Foreign Direct Investment in the United States (Form BE-605);annual reporting of financial and operating data concerning the U.S. real property on the Annual Survey of Foreign Direct Investment in the United States (Forms BE-15A, BE-15B, BE-15(EZ), and BE-15…

Considerations for HK/SG Residents investing in UK Real Estate

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·Dividends – oFrom April 2016 the Dividend Tax Credit will be replaced by a new tax-free Dividend Allowance. oThe Dividend Allowance means that you won’t have to pay tax on the first £5,000 of your dividend income, no matter what non-dividend income you have. oYou’ll pay tax on any dividends you receive over £5,000 at the following rates: §7.5% on dividend income within the basic rate band §32.5% on dividend income within the higher rate band §38.1% on dividend income within the additional rate band §Personal Allowance: £11,000 §Basic Rate Limit: £32,000 §Higher Rate Threshold: £43,000 §Additional rate band: Over £150,000 oNote wording of the treaty - 2. However, such dividends may also be taxed in the Contracting State of which the company paying the dividends is a resident and according to the laws of that State, but if the recipient is the beneficial owner of the dividends the tax so charged shall not exceed: §(a) 5 per cent of the gross amount of the dividends if the beneficial owner is a c…