More details via Chartered Professional Accountants of Canada (CPA Canada) on the capital gains inclusion rate increase--including several outstanding issues to do with these important #tax changes that require further clarification before the draft legislation is tabled. https://lnkd.in/gn2E2rDf
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Honoured to have served as the country reporter for Canada in IBFD's "Dispute Resolution under Tax Treaties", edited by Guglielmo Maisto. My report reviews Canada’s policies and practices with respect to Mutual Agreement Procedures under Canada’s network of tax treaties. Many thanks to friends and colleagues who provided useful insight during the preparation of the chapter, including Claire Balas, Connor Campbell, Laurie Goldbach, Patricia Lattimore, Ashley Perley, Daniel Sandler and Mark Tonkovich. #tax #taxlitgation #internationaltax
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The Australian Government’s proposed reduction to the managed investment trust (MIT) withholding tax rate from 30% to 15% promises to encourage more foreign investment in Australia’s growing Build-to-Rent (BTR) market. But, do the changes go far enough? A&M Tax experts examine the Government’s proposed laws, its potential limitations, and what further detail is needed while also highlighting the State and Territory BTR incentives offered and analyze the final piece in the puzzle: Goods and services tax (GST). Learn more: https://okt.to/ngkrKB #australiatax #realestate
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[ Offshore Tax ] Exploring the CSG and CRDS: France’s Social Contributions. With Hervé Israel and Derren Joseph EA #USFranceTaxAgreement #ForeignTaxCredit #CSGandCRDS #TaxUnderstanding #InternationalTaxation #TaxCompliance #TaxCredits #IRSUpdate #TaxPolicy #DiplomaticRelations #TaxationAgreement #CrossBorderTax #TaxationUpdates #SocialSecurity #TaxReforms #TaxpayerBenefits #AmendedReturns #GlobalTaxation #TaxChanges #InternationalRelations
International Tax Advisory for Private Clients || Board Member || Chair - Tax Working Group at Moores Rowland Asia Pacific || Chair - Asian Branch of the International Business Structuring Association
[ Offshore Tax ] Exploring the CSG and CRDS: France’s Social Contributions. In 2019, the United States and the French Republic memorialized an understanding through diplomatic communications. This understanding stated that the French Contribution Sociale Generalisee (CSG) and Contribution au Remboursement de la Dette Sociale (CRDS) taxes are not social taxes covered by the Agreement on Social Security between the two countries. Accordingly, the IRS will not challenge foreign tax credits for CSG and CRDS payments on the basis that the Agreement on Social Security applies to these taxes. The IRS’s change in policy means individual taxpayers who paid or accrued these taxes, but did not claim them, can file amended returns to claim a foreign tax credit. #USFranceTaxAgreement #ForeignTaxCredit #CSGandCRDS #TaxUnderstanding #InternationalTaxation #TaxCompliance #TaxCredits #IRSUpdate #TaxPolicy #DiplomaticRelations #TaxationAgreement #CrossBorderTax #TaxationUpdates #SocialSecurity #TaxReforms #TaxpayerBenefits #AmendedReturns #GlobalTaxation #TaxChanges #InternationalRelations
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Did you know? The top 20% of income earners in Canada are taking care of two-thirds of all the income tax collected. Is this a fair share? Let us know what you think in the comments below #businessowners #realestatetoronto #realestateontario #investing #investingtips #realestateinvesting #taxes #canadiantaxes #incometax #taxtherich
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Public Relations Consultant at Hayden T Joseph & Co. (DBA "Advanced American Tax") - a member of Moores Rowland Asia Pacific
[ Offshore Tax ] Exploring the CSG and CRDS: France’s Social Contributions. With Hervé Israel and Derren Joseph EA #USFranceTaxAgreement #ForeignTaxCredit #CSGandCRDS #TaxUnderstanding #InternationalTaxation #TaxCompliance #TaxCredits #IRSUpdate #TaxPolicy #DiplomaticRelations #TaxationAgreement #CrossBorderTax #TaxationUpdates #SocialSecurity #TaxReforms #TaxpayerBenefits #AmendedReturns #GlobalTaxation #TaxChanges #InternationalRelations
International Tax Advisory for Private Clients || Board Member || Chair - Tax Working Group at Moores Rowland Asia Pacific || Chair - Asian Branch of the International Business Structuring Association
[ Offshore Tax ] Exploring the CSG and CRDS: France’s Social Contributions. In 2019, the United States and the French Republic memorialized an understanding through diplomatic communications. This understanding stated that the French Contribution Sociale Generalisee (CSG) and Contribution au Remboursement de la Dette Sociale (CRDS) taxes are not social taxes covered by the Agreement on Social Security between the two countries. Accordingly, the IRS will not challenge foreign tax credits for CSG and CRDS payments on the basis that the Agreement on Social Security applies to these taxes. The IRS’s change in policy means individual taxpayers who paid or accrued these taxes, but did not claim them, can file amended returns to claim a foreign tax credit. #USFranceTaxAgreement #ForeignTaxCredit #CSGandCRDS #TaxUnderstanding #InternationalTaxation #TaxCompliance #TaxCredits #IRSUpdate #TaxPolicy #DiplomaticRelations #TaxationAgreement #CrossBorderTax #TaxationUpdates #SocialSecurity #TaxReforms #TaxpayerBenefits #AmendedReturns #GlobalTaxation #TaxChanges #InternationalRelations
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International Tax Advisory for Private Clients || Board Member || Chair - Tax Working Group at Moores Rowland Asia Pacific || Chair - Asian Branch of the International Business Structuring Association
[ Offshore Tax ] Exploring the CSG and CRDS: France’s Social Contributions. In 2019, the United States and the French Republic memorialized an understanding through diplomatic communications. This understanding stated that the French Contribution Sociale Generalisee (CSG) and Contribution au Remboursement de la Dette Sociale (CRDS) taxes are not social taxes covered by the Agreement on Social Security between the two countries. Accordingly, the IRS will not challenge foreign tax credits for CSG and CRDS payments on the basis that the Agreement on Social Security applies to these taxes. The IRS’s change in policy means individual taxpayers who paid or accrued these taxes, but did not claim them, can file amended returns to claim a foreign tax credit. #USFranceTaxAgreement #ForeignTaxCredit #CSGandCRDS #TaxUnderstanding #InternationalTaxation #TaxCompliance #TaxCredits #IRSUpdate #TaxPolicy #DiplomaticRelations #TaxationAgreement #CrossBorderTax #TaxationUpdates #SocialSecurity #TaxReforms #TaxpayerBenefits #AmendedReturns #GlobalTaxation #TaxChanges #InternationalRelations
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Inland Revenue NZ has just issued five Public Rulings and accompanying commentary which is highly relevant to some of our clients with US connections. These clarify the income tax treatment and availability of foreign tax credits or other forms of double taxation relief for NZ investors in a US limited liability company (US LLC) that is taxed on a fiscally transparent basis as a partnership in the US, but as a foreign company in NZ. The Rulings demonstrate the respective tax treatments where the interest in the US LLC is classified as under the foreign investment fund (FIF) threshold, a FIF or a controlled foreign company (CFC); where different FIF methods are used and where there is a non-attributing active FIF or CFC. This is super technical but can be a big deal - especially for our investor migrant clients. Some clients only come to us after moving to NZ without the benefit of expert pre-migration tax advice. It is much smarter and more economic to scenario plan well in advance. #tax #privatewealth #residencybyinvestment #familyoffice
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Canada Revenue Agency - Agence du revenu du Canada feels your bare trust filing pain. It will no longer require bare trusts to file a T3 return for the 2023 tax year unless it makes a direct request for these filings. This announcement recognizes the unintended impact this requirement had on many Canadians. Read more: https://ow.ly/k2tw50R6T3Z #Tax #Alert #TaxAlert
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Are you a UK non-domiciled resident with foreign income or investments? The upcoming changes to non-domicile tax rules might impact you. One key point is the Temporary Repatriation Facility (TRF). This two-year window (April 2025 - April 2027) offers a chance to bring back previously untaxed overseas income and gains at a reduced rate of 12%. This could be a significant tax-saving opportunity, but it's important to understand the details. Here's why I (we) recommend considering the Temporary Repatriation Facility: Reduced Tax Burden: Potentially save a significant amount compared to regular income tax rates under the new system. Peace of Mind: Consolidate your finances and simplify your tax affairs. However, there are factors to consider: Time Sensitive: The Temporary Repatriation Facility is a limited-time offer, so don't miss the window! Seek Guidance: The Temporary Repatriation Facility can be complex, and professional advice can ensure you maximize its benefits. Let's Chat! Whether you have questions about the Temporary Repatriation Facility, the new non-dom rule (non-domicile rule), or your overall tax strategy, feel free to reach out. I'm here to help you navigate the ever-changing tax landscape. . . . Visit us to know more: https://lnkd.in/e_cjSych #uk #Taxfiling #Returns #income #Returns #accounting #taxpreparation #finance #FinbridgeAdvisors #taxes #Finbridge
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