A recent ruling from the Tax Court of Canada underscores the significance of tenants verifying their landlords' residency status in adhering to any obligations to withhold taxes in accordance with Part XIII of the Income Tax...more
On July 21, 2023, New Jersey Governor Phil Murphy signed Assembly Bill No. S3128/A4694 into law, which implements an aggressive tax treatment of nonresidents who work for New Jersey employers. The law essentially adopts the...more
Muchos ciudadanos americanos que viven en el extranjero no presentan su declaración de impuestos en Estados Unidos de América (“EUA”) por diversas cuestiones. Generalmente, esto sucede porque se tiene la creencia que no es...more
For Americans and other foreign residents, Mexico is a very attractive country to live and work, because of its weather, rich culture, delicious food, friendly locals, and cost of living. And in an increasingly global...more
The UK’s First-tier Tribunal recently considered the application of the “place of effective management” residency tie-breaker test found in double tax treaties in the recent case of Haworth and others v HMRC [2022] UKFTT 34...more
In a previous post, we provided an overview for determining a person's U.S. income tax residency status under the substantial presence test (the "SPT"), a test which relies on a mathematical formula for computing an...more
What does it mean to be a U.S. income taxpayer? Very simply, it means that you are taxable on your worldwide income and gains, even if you don't live full-time in the U.S. Any U.S. citizen is likely already familiar with this...more
Employees working remotely outside the UK during Covid-19 may create – and may already have created – expensive tax liabilities for themselves and their employers....more
The guidelines for determining an Individual’s tax residency are as follows: - An Individual Taxpayer is a resident based on the laws of one treaty-partner country and is considered to be a resident of that country for...more
In This Issue: - Two Combined Reporting Decisions Highlight Issues Involving “Permissive” Combined Reporting - New York State Corporate Tax Reform Legislation Enacted – What You Need to Know - Appellate Court...more
A taxpayer we will call John worked for a savings bank in New York that was acquired by Washington Mutual Bank. John participated in the New York bank’s supplemental executive retirement plan (SERP) and its deferred...more