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Showing posts from September, 2019

Economic Substance Requirements in the British Virgin Islands (BVI)

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The BVI is among the most popular jurisdictions for offshore structures.   http://www.mooresrowland.tax/2018/05/pros-and-cons-of-bvi-entity.html
But things are changing and for a number of reasons, it is losing its appeal -  http://www.mooresrowland.tax/2017/07/bvi-secrecy-no-more.html http://www.mooresrowland.tax/2018/05/uk-forces-overseas-territories-to-set.html
Now it seems that the new rules around substance is hitting them pretty hard - 

The BVI government has introduced a new Act with Economic Substance Requirements for certain legal entities effectively applicable from 1 January 2019, with a six-month transitional period for existing legal entities. The legislation is introduced based on the recommendations of the BEPS project developed by the OECD to combat tax evasion by multinationals which are shifting profits from high tax jurisdictions to entities in low/zero tax jurisdictions but which entities have no adequate economic substance locally. 
Similar legislation is introduced…

The Best Jurisdiction for US Citizens and Green Card Holders? Puerto Rico

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Puerto Rico Tax Incentives:


US citizen?
1. pay ZERO US federal income tax,  2. only a 4% corporate tax for my businesses and  3. ZERO capital gains and dividends tax.


Puerto Rico is a commonwealth of the US. That means that most things here fall under US federal law, like immigration and customs and border enforcement.  But Puerto Rico’s tax system is independent from the US. Puerto Rico has its own tax agency, like the IRS. That’s what makes Puerto Rico unique. It’s a part of the US, but tax-wise, it’s not.

If you’re a regular employee, don’t be discouraged. If you can work anywhere – which is increasingly common these days – see if you can switch to be a contractor for your company. You’ll be able to enjoy the same tax privileges.


How to slash your corporate tax rate to only 4%

1. You incorporate a business in Puerto Rico that’s providing a service. And that service is being sold to people outside of Puerto Rico. Your service could be management consulting, accounting, legal services…

10 US Tax Rules For Foreign Entertainers And Athletes

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Given the growth of the sports industry not only within North America, but also internationally, it is increasingly critical that foreign athletes and entertainers become educated regarding the United States’ taxation of their income.

1. The first step in determining the U.S. taxation of a so-called “foreign” athlete or entertainer (namely an athlete that is not a U.S. citizen) is residency for tax purposes — specifically, whether the athlete or entertainer is a “resident alien” or a “nonresident alien.”

2. Resident aliens, as opposed to nonresident aliens, are subject to U.S. tax on their worldwide income. 
Here's more on this - http://www.mooresrowland.tax/2014/10/irs-information-letter-on-treatment-of.html

3. Nonresident aliens, by contrast, are typically subject only to tax on income that can be “sourced” in the U.S.

4. If a foreign athlete or entertainer is not a U.S. citizen, the athlete or entertainer is considered a resident for purposes of U.S. income tax if the athlete …

Investing in the USA

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We commonly speak with investors from Asia and elsewhere who are interested in investing the USA.  Most commonly the investment is real estate, but we work with more sophisticated investors who have an appetite for US businesses as well.
Naturally foreign (also called Non Resident Alien or NRA) investors, want to know how investment into American business should best be structured.
If you're an NRA investing in US Real Estate, please read this - http://www.mooresrowland.tax/2017/05/are-you-non-american-nra-and-own-us.html





Ownership Structures for Foreign Investors
An NRA can acquire U.S. assets using several alternative ownership structures. The NRA's goals and priorities dictate the type of structure that is used. Each alternative has its own advantages and disadvantages – there is no perfect structure.














Direct investment (assets owned by the NRA) is simple.  Assets are held in the NRA's own name and is subject to only one level of tax on the disposition.  If the asset is held f…

IRS offers tax relief to expats who renounce U.S. citizenship

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source: https://www.irs.gov/individuals/international-taxpayers/relief-procedures-for-certain-former-citizens

On this page...IntroductionBackgroundRelief ProceduresRelief Procedures FAQsReferences/Related TopicsIntroductionThe IRS announced procedures for certain persons who have relinquished, or intend to relinquish, their United States (U.S.) citizenship and who wish to come into compliance with their U.S. income tax and reporting obligations and avoid being taxed as a “covered expatriate” under section 877A of the U.S. Internal Revenue Code (IRC).  Please read all information for these procedures including the Frequently Asked Questions and Answers (FAQs) to determine eligibility. Relinquishing U.S. citizenship and the tax impacts of relinquishing U.S. citizenship are serious matters that involve irrevocable decisions. Consider consulting legal counsel before making any decisions about relinquishing U.S. citizenship.

The Department of the Treasury, the Department of State, the Inter…