income or profit from real estate investments) and thus also the need for a level playing field across Europe was (and still is) more urgent.This paper reviews current Eurotaxation of passive incomes, focusing on the non-EU investor wishing to establish a subsidiary in Europe to obtain the ...
taxation on their income and assets. In Canada the principles of FATCA have been brought into local laws, pursuant to the Intergovernmental Agreement (IGA) signed between Canada and the United States. Under the IGA, HSBC will be reporting information relating to U.S. accounts to the Canada ...
“Gold however has its fans in the East and gold is moving from West to the East. When Western central banks do sell as the Bank of England did in the late 90′s, as little Venezuela did in the first quarter and is probably doing now, typically those are moments to pay attention bec...
The answer lies in a well-known principle dealing with the deferral of the taxation of income (the “deferral principle”). The deferral principle holds that the deferral of the taxation of income is the equivalent of not allowing a deferral, but instead exempting from tax the income earned ...
American investors could avoid taxation by investing in foreign business entities that generated passive income before the mid-1980s. This tax loophole has since been closed, however, and U.S. investors who hold such foreign assets must declare this income in passive foreign investment companies (...
participation tests. A passive participation in an income-producing venture is participation that is not regular, continuous, and substantial. Income-producing actions, in which the taxpayer passively participates, are passive income and loss. Passive activity rules limit the deductibility of any passive...
attribution of incomeDIR / passive incomeapproved issuer levy (AIL)foreign investor tax creditNew ZealandThis article examines the international taxation of dividend, interest and royalty income derived through a trust. It concludes that New Zealand's general princBrabazon, Mark...