October 2019

Perpetual Nomad? Is it possible to pay taxes nowhere?

  I previously wrote about flag theory here – https://www.mooresrowland.tax/2019/05/flag-theory-aka-perpetual-traveler.html Now the question often asked is this.  If I keep moving and don’t spend enough time to trigger tax residency in any one country.  Am I legally free from taxes full stop? If you’re American?  The answer is here –  https://www.htj.tax/streamlined/  https://www.htj.tax/us-pre-immigration-planning https://www.mooresrowland.tax/2019/09/the-best-jurisdiction-for-us-citizens.html As for everyone […]

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States – Business Activity Tax Nexus Guidance

Here’s what we previously wrote on Wayfair and sales and use taxes –  https://www.mooresrowland.tax/2018/12/supreme-court-abolishes-physical.html https://www.mooresrowland.tax/2019/10/navigating-post-wayfair-world.html Some states are going further and now corporate income tax nexus can be triggered without physical presence Wayfair has, for now, answered the question (at least, in part) of whether economic activity creates substantial nexus under the Commerce Clause for purposes

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Ultimate Guide to Singapore Family Offices

I.  Overview Family offices have emerged as a pivotal player in the complex world of wealth management and financial planning. These exclusive entities cater to the multifaceted needs of ultra-high-net-worth families, offering a holistic approach to managing wealth, assets, and legacies.  A. What is a Family Office? A family office can be likened to a

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Taxation of Digital Products

  For background, please read –  US – https://www.mooresrowland.tax/2019/10/navigating-post-wayfair-world.html EU – https://www.mooresrowland.tax/2019/10/distance-selling-in-eu.html Digital Nomads in Asia – https://www.mooresrowland.tax/2018/04/tax-responsibilities-of-digital-nomads.html US Digital Nomads – https://www.mooresrowland.tax/2018/03/non-us-digital-nomads-working-for.html   Taxing remote businesses   For a government to levy corporate tax on a foreign firm, tax rules require a “nexus” or link between the taxpayer and the taxing jurisdiction, typically in the form of physical

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Transfer Pricing and CFCs in Indonesia

Overview Principal legislation The principal transfer pricing legislation is: the Indonesian Income Tax Law No. 7 of 1983, as last amended by Income Tax Law No. 36 of 2008 (ITL); Government Regulation No. 74 of 2011 concerning Procedures for Implementing Rights and Obligations of Taxation Liability; the Director General of Taxes Regulation No. PER-43/PJ/2010 (PER-43)

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Failure to File IRS Form 8854 after Surrendering a Green Card or after Expatriation

I was sharing with my colleague that we have had 5 inquiries this week on a single topic. US exposed persons who gave up US passports or Green Cards but failed to file Form 8854 – Initial and Annual Expatriation Statement – https://www.irs.gov/forms-pubs/about-form-8854 1. Is it the end of the world? No 2. Does it mean

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IRS Issues Guidance on Hard Forks, Airdrops and Soft Forks

On October 9, 2019, the U.S. Internal Revenue Service (IRS) released frequently asked questions on virtual currency transactions (FAQ) and Revenue Ruling 2019-24 (Revenue Ruling). The long-anticipated guidance on virtual currency transactions primarily builds on previous guidance the IRS provided in Notice 2014-21.  Summary The FAQ generally expands on the guidance and examples provided in Notice 2014-21 and applies

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