News & Analysis as of

Non-Resident Income Taxes

New Non-Resident Speculation Tax in Ontario

by Bennett Jones LLP on

The provincial government announced today that effective April 21, 2017, it is imposing a 15-percent non-resident speculation tax on the purchase or acquisition of interests in residential property located in the Greater...more

The Flat Tax for individuals transferring their tax residence to Italy

The 2017 Budget Law 2017 introduced a substitute tax optional regime (equal to € 100,000 per each tax year) for non-resident individuals wishing to transfer their tax residence to Italy. ...more

La "Flat Tax" per i neo-residenti non domiciliati

Con la legge di bilancio 2017, il legislatore ha introdotto un regime opzionale di tassazione forfetaria (pari a € 100.000 annui) per le persone fisiche non residenti che intendono trasferire la residenza fiscale nel nostro...more

Tax Round Up - April 2017

by Proskauer Rose LLP on

Welcome to the Tax Round Up, the first edition of what will be a regular bulletin highlighting the latest tax developments relevant to UK companies and asset managers. We plan to produce this monthly with the next one in...more

A Guide to UK Tax on Commercial Real Estate: Non-Residents

by King & Spalding on

1. Introduction - This client alert provides a summary of key UK tax considerations when a nonresident invests into UK commercial real estate. There are a number of holding structures for investment into UK real estate...more

N.Y.’s 2018 Budget Proposal: Tax Proposals To Watch

by Farrell Fritz, P.C. on

Last month, Governor Cuomo presented his budget proposal for NY State’s 2017- 2018 fiscal year. Included in the proposal were a number of tax provisions that should be of interest to closely-held businesses and their owners....more

Update On The Exemption For Non-Residents From Payroll Withholding

by Dentons on

The Canada Revenue Agency (“CRA”) recently introduced a program to ease the administrative burden associated with Canadian withholding on the salary, wages, or other remuneration paid to non-resident employees performing...more

Spotlight On Alabama: A Busy Tax Year in Review

by Baker Donelson on

It has been a busy year for developments in Alabama state taxation. In this tax alert we review many of the significant developments that have occurred over the last 12 months....more

Tax-Savvy Planning for Foreign Business Owners Seeking Temporary U.S. Residence: Alternatives to the EB-5 Visa

by Gerald Nowotny on

The EB-5 Visa program has been widely promoted as a legal basis for foreign business owners to gain conditional residency followed by permanent residency in the United States. The program is a great solution to the...more

Another Significant Development in the Statutory Residency Area!

by Hodgson Russ LLP on

There are always “traps” in the tax law, where taxpayers unwittingly walk into a tax problem that they didn’t see coming. In the residency area, some taxpayers often got trapped on a move-in or move-out situation, with the...more

Out-of-State Attorney Not Subject to New York State Income Tax

by Hodgson Russ LLP on

We have all heard the jokes. “How many lawyers does it take to screw in a light bulb?” “Why won’t sharks attack lawyers?” “What’s the difference between an accountant and a lawyer?” Or, “How many lawyer jokes are there?”...more

ALJ Strikes Down Aggressive Attempt by New York State Department of Taxation and Finance to Tax Nonresident Attorney

by Reed Smith on

An Administrative Law Judge (“ALJ”) with the New York State Division of Tax Appeals recently struck down an aggressive attempt by the New York State Department of Taxation and Finance (the “Department”) to tax the income of a...more

The Ohio Supreme Court Places Limitations on the Ohio Bright Line Income Tax Residency Presumption

by BakerHostetler on

On July 8, 2015, the Ohio Supreme Court found that Ohio nonresidents may not claim the benefit of the Ohio “bright line” presumption of nonresidency for income tax purposes if the taxpayer attests to having a domicile outside...more

Could Maryland v. Wynne Result in NY Refunds?

by Hodgson Russ LLP on

A new U.S. Supreme Court case, Maryland v. Wynne, will likely have a broad impact on various state taxation schemes, and it could create the potential for refunds for numerous taxpayers. Taxpayers who have paid tax to...more

Guide To Doing Business in New Zealand: Taxation (Updated)

TAXATION - It is not possible to give a complete outline of the scope of the taxation system in this guide. A brief outline of the basic taxation principles and some of the major forms of taxation are discussed below....more

Australia: Tax Changes on the Horizon for Expatriates Working in Australia

by Littler on

In May 2015, the Abbott Government announced that, as part of its objectives for the Australian federal budget, it will reform the tax residency rules by creating tougher rules and higher income tax bills for the approximate...more

New York’s Highest Court Considers Constitutionality of Retroactive Taxing Statute

by Hodgson Russ LLP on

Questioning the constitutionality of state personal income tax provisions seems to be all the rage these days. On the heels of the Supreme Court’s decision in Comptroller v. Wynne discussed in our recent blog post, New York’s...more

Wynne Is a Win for Corporate Taxpayers

by Faegre Baker Daniels on

On May 18, 2015, the U.S. Supreme Court decided Comptroller of the Treasury of Maryland v. Wynne, No. 13-485, holding that the absence of a credit against the local portion of the state’s personal income tax scheme was an...more

Triple Threat: U.S. House Subcommittee Considers Three State Tax Bills

On June 2, 2015, the U.S. House of Representatives Judiciary Committee’s Subcommittee on Regulatory Reform, Commercial and Antitrust Law conducted a hearing on three state tax bills: the Mobile Workforce State Income Tax...more

Ohio Supreme Court Rules City of Cleveland’s Taxation of Nonresident NFL Players’ Compensation Out-Of-Proportion to Games Played...

by McDermott Will & Emery on

On April 30, 2015, out-of-state professional football players earned victories against the City of Cleveland, Ohio. In a pair of cases decided by the Ohio Supreme Court, the court first struck the City’s method of allocating...more

Five Things You Should Know About the United States Supreme Court decision in Maryland v. Wynne

On May 18, 2015, the United States Supreme Court ruled in a 5-4 decision that Maryland’s personal income tax scheme violates the Commerce Clause of the United States Constitution by denying residents a full credit for...more

U.S. Supreme Court’s Wynne Decision Calls New York’s Statutory Resident Scheme into Question

by McDermott Will & Emery on

On May 18, the U.S. Supreme Court issued its decision in Comptroller of the Treasury of Maryland v. Wynne. In short, the Court, in a five-to-four decision written by Justice Alito, handed the taxpayer a victory by holding...more

Supreme Court Rules that Dormant Commerce Clause Limits Maryland’s Taxing Powers over Its Residents

The U.S. Supreme Court issued its long-awaited decision in Comptroller of the Treasury of Maryland v. Wynne on May 18. In a split 5-4 decision, the Court struck down as unconstitutional a feature of Maryland’s income tax...more

Supreme Court Rules on Limits of State Taxing Authority – Refund Claims in Order

by Goulston & Storrs PC on

In Comptroller v. Wynne, the Supreme Court ruled that individuals who earn income in states in which they do not reside may be entitled to refunds if the taxes they pay to the nonresident state are not fully creditable...more

Supreme Court Mandates State Income Tax Credits, Pretty Much

by Charles (Chuck) Rubin on

Maryland imposes income taxes on its residents. There is a state level income tax, and a county level tax. If a Maryland resident incurs income in other states and pays state income tax to those other states, there is a...more

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