News & Analysis as of

Non-Resident Income Taxes

Proposed UK Real Estate Tax Regime Targets Offshore Investors' Capital Gains

by Jones Day on

The Situation: Historically, the United Kingdom has not taxed capital gains on real estate disposals when the seller was not a UK resident. The Development: Coming into line with most of the world's jurisdictions, the UK...more

Asset Management Regulatory Roundup - November 2017 - Issue 11

by Dechert LLP on

A compact summary of the most recent regulatory and tax developments relevant to the UK asset management industry. This issue includes details on ESMA’s updated Q&As on the key information document requirements for PRIIPs;...more

UK Autumn Budget 2017 – the key measures impacting business

by White & Case LLP on

The Chancellor, Philip Hammond, has announced the Autumn Budget 2017. Alongside the headline-grabbing abolition of SDLT for first-time buyers on homes up to £300,000, and on the first £300,000 of properties up to £500,000,...more

The Netherlands - Budget 2018 - Dividend withholding tax and non-resident taxation

by Dentons on

On 19 September 2017, the Dutch government released the State’s Budget for the year 2018. The Budget includes a draft bill to expand the dividend withholding tax exemption to tax treaty countries, to introduce a withholding...more

Senate Bill 628 Update

by Smith Anderson on

Two previous Tax Alerts, Tax Provisions in the 2017 Budget Bill (June 20, 2017) and Tax Legislation Enacted During the Regular Session of the 2017 North Carolina General Assembly (June 30, 2017), summarized the major tax...more

Ukraine adopts the list of organizational forms of non-residents for transfer pricing purposes

by DLA Piper on

On July 4, 2017, the Cabinet of Ministers of Ukraine adopted Resolution No. 480 on the approval of the list of organizational forms of non-residents who do not pay income (corporate) tax and/or are not tax residents of the...more

U.S Tax Court Bounces Rev. Rul. 91-32: Sales of Partnership Interests by Foreign Partners May Not be Subject to U.S. Tax

by Dickinson Wright on

The practice of tax law is an exercise of statutory interpretation. A recent opinion of the U.S. Tax Court, Grecian Magnesite Mining, Indust. & Ship. Co. v. C.I.R., 149 T.C. No. 3 (July 13, 2017), is illustrative. Grecian...more

Newsflash: Tax Court Reverses IRS Revenue Ruling

by Dechert LLP on

A recent U.S. Tax Court case, Grecian Magnesite (149 T.C. No. 3, July 13, 2017), has declared invalid the long-standing U.S. government position that a non-U.S. person’s sale of an interest in a partnership (in this case, a...more

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

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