USA: PFIC Regs Released: Reporting Required on 2013 Tax Returns

USA: PFIC Regs Released: Reporting Required on 2013 Tax Returns

On December 30, 2013, the U.S. Internal Revenue Service (IRS) released temporary, final and proposed regulations in relation to passive foreign investment companies (PFICs). The new regulations confirm that U.S. citizens and residents who own shares in PFICs will be required to provide annual reporting on Form 8621 for all PFICs starting with their... »

BELGIUM: Proposed Changes Affecting Net Pay of Those Enjoying Expatriate Concessions

BELGIUM: Proposed Changes Affecting Net Pay of Those Enjoying Expatriate Concessions

The Belgian government issued draft legislation amending the rules for calculating nonresident personal income tax during the Christmas holidays. The important consequences of these measures, if passed, are: • the category of nonresident taxpayers with an abode in Belgium will be abolished; • expatriates benefiting from the expatriate tax concessions who have a foreign... »

BELGIUM: Threat Looms of Audits for Taxpayers Claiming Expatriate Concessions

BELGIUM: Threat Looms of Audits for Taxpayers Claiming Expatriate Concessions

The Belgian tax authorities have indicated they will be undertaking targeted audits of taxpayers benefiting from Belgium’s expatriate tax concessions. Why This Matters This enhanced scrutiny by the Belgian tax authorities means that if a taxpayer is not compliant with the rules, the taxpayer (and possibly his or her employer) could be subject to... »

UNITED KINGDOM: Draft 2014 Finance Bill Holds Plenty of Measures for Individuals

UNITED KINGDOM: Draft 2014 Finance Bill Holds Plenty of Measures for Individuals

The U.K. government’s draft 2014 Finance Bill was published on 10 December 2013. This draft legislation relates to announcements made in the Chancellor’s Budget speech on 21 March 2013 and some of the measures announced in his Autumn Statement last week (see Flash International Executive Alert 2013-161, 6 December 2013, for details of the... »

Managing HR in a Global Downturn!

Managing HR in a Global Downturn!

Red Recruit work with Global Mobility professionals and connected associates, servicing the industry and 2013 has shown a surge in the growing markets with businesses investing in order to realise future returns on investment. However, there seems to be some gaps in the mobility’s delivery, as the EY Global Mobility Effectiveness Survey 2013 indicates... »

Caracas is now the world’s most expensive place for expatriates

Caracas is now the world’s most expensive place for expatriates

For the first time Venezuela’s capital city has become the most expensive place in the world for expatriates. This is among the findings of the latest Cost of Living survey by ECA International, the world’s leading provider of knowledge, information and technology for the management and assignment of employees around the world. The ongoing... »

UNITED KINGDOM: Autumn Statement with Tax Proposals and Announcements Presented

UNITED KINGDOM: Autumn Statement with Tax Proposals and Announcements Presented

The Chancellor of the Exchequer, on 5 December 2013, delivered the U.K.’s Autumn Statement. The statement is an annual update by the Chancellor to Parliament on the taxation and spending plans of the government. (For coverage of last year’s Autumn Statement, see Flash International Executive Alert 2012-220, 5 December 2012.) The highlights with respect... »

SPAIN: Case Considers Tax Deductibility of Stock Options

SPAIN: Case Considers Tax Deductibility of Stock Options

In this Flash International Executive Alert we examine the recent judgment issued by Spain’s Supreme Court (Tribunal Supremo) regarding the tax deductibility, for Corporate Income Tax purposes, of the expenses incurred by a company as a result of “stock option” plans provided to employees. This judgment comes following a review of an appeal filed by... »

NEW ZEALAND: Tax Bill Changes Treatment of Employee Benefits

NEW ZEALAND: Tax Bill Changes Treatment of Employee Benefits

New Zealand’s omnibus Taxation (Annual Rates, Employee Allowances, and Remedial Matters) Bill (the “Bill”) was recently introduced. In this Flash International Executive Alert we focus on one of the headline measures in the Bill, which may potentially impact on individuals – including those on international assignment – and their employers. For the complete article,... »

COSTA RICA: Modifications to Income Tax Brackets, Credits

COSTA RICA: Modifications to Income Tax Brackets, Credits

Costa Rica’s Ministry of Finance has modified the income tax brackets for the taxable year 2013-2014 (i.e., taxable year from 1 October 2013 to 30 September 2014) in accordance with changes in the Consumer Price Index as determined by the National Statistical and Census Institute. The tables below reflect the new income tax brackets,... »

France: Tax Fraud, Trusts, and EU Developments

France: Tax Fraud, Trusts, and EU Developments

In this Flash International Executive Alert we highlight a few tax developments that may affect individuals – including those on international assignment – and their multinational employers. Bill on Tax Fraud On November 5, 2013, the French National Assembly approved, in a final vote, the bills on the fight against tax fraud (Le projet... »

UNITED KINGDOM: Capital Gains and Residence Case Emphasizes Importance of Record-Keeping

UNITED KINGDOM: Capital Gains and Residence Case Emphasizes Importance of Record-Keeping

The First Tier Tribunal (FTT) in the U.K. has recently issued its decision in a case concerning an appeal against assessments issued by HM Revenue & Customs (HMRC) to the appellants for capital gains tax payable for each of the four years ending 5 April 2005. The assessments were issued on the basis that... »

BRAZIL: Court Rules on Imposing Social Security Taxation on Stock Options

BRAZIL: Court Rules on Imposing Social Security Taxation on Stock Options

A Brazilian court has concluded that a local company (a subsidiary of a Swedish company) is not obligated to collect social security contributions on stock option transactions. The decision was issued by the Tribunal Regional (TRF – 3rd Region – São Paulo ) and can be seen as an important precedent favorable to taxpayers.... »

France: Social Security Finance Bill Presented, Measures for French Border Workers

France: Social Security Finance Bill Presented, Measures for French Border Workers

In this Flash International Executive Alert, we focus on the French social security finance bill (Projet de loi de financement de la Sécurité sociale pour 2014 or ‟PLFSS”), which was adopted in its first reading in the National Assembly on 29 October 2013. We first discuss a new measure in the PLFSS that applies... »

UNITED KINGDOM: Plans to Facilitate Trade, Investment, and Visits by Chinese Nationals

UNITED KINGDOM: Plans to Facilitate Trade, Investment, and Visits by Chinese Nationals

The U.K. government is taking additional steps to encourage trade and investment between the U.K. and the People’s Republic of China (PRC) and facilitate the entry of Chinese nationals (tourists, students, teachers, researchers, entrepreneurs, investors, and workers, etc.) into the United Kingdom.1 Press reports over several months have claimed that Chinese nationals are deterred... »

BELGIUM: Guidance Issued on Per Diems for Short-Term Assignments

BELGIUM: Guidance Issued on Per Diems for Short-Term Assignments

In a recent circular letter,1 the Belgian tax authorities have clarified the conditions and circumstances where daily allowances provided to employees or company directors on business trips abroad longer than 30 days may be considered as tax-free reimbursement of costs attributable to the employer. Circular Confirms Existing Ruling Practice The conditions mentioned in the... »

UNITED STATES: E-Verify Resumes Operations with End of Government Shut-down

UNITED STATES: E-Verify Resumes Operations with End of Government Shut-down

E-Verify has resumed operations following the re-opening of the U.S. federal government. Some E-Verify features and service were non-operational due to the partial federal government shut-down that lasted nearly two weeks. All E-Verify features and services are now available. The following information addresses questions on how the federal government’s shut-down affected E-Verify and Form... »

Weichert Workforce Mobility Launches Survey to Identify Relocation Best Practices in Latin America

Weichert Workforce Mobility Launches Survey to Identify Relocation Best Practices in Latin America

MORRIS PLAINS, N.J., October 18, 2013 – In an ongoing effort to provide today’s HR leaders with they insight they need to optimize the management of their mobile talent, Weichert Workforce Mobility—one of the world’s leading workforce mobility management companies—has launched a groundbreaking survey of Latin America relocation trends. The results of this survey... »

SOUTH AFRICA: Prepare for FATCA compliance

SOUTH AFRICA: Prepare for FATCA compliance

October 23:  Officials with the South African Revenue Service (SARS) have indicated a commitment to enter into a FATCA* Model 1 Intergovernmental Agreement (IGA) with the United States. *Foreign Account Tax Compliance Act (FATCA) Accordingly, FATCA would be a reality for South African financial institutions, and these entities would need to consider the effects... »

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