UNITED STATES: IRS Guidance on Sec. 911 for Four Countries

UNITED STATES: IRS Guidance on Sec. 911 for Four Countries

On March 24, 2014, the U.S. Internal Revenue Service (IRS) released an advance copy of Rev. Proc. 2014-25, which concerns individuals who failed to meet the eligibility requirements of either the bona fide residence test or the physical presence test under U.S. Internal Revenue Code (I.R.C.) section 911(d)(1) – and thus may not exclude... »

UNITED KINGDOM: Amended Legislation to Prevent Tax Avoidance Using Dual Contracts

UNITED KINGDOM: Amended Legislation to Prevent Tax Avoidance Using Dual Contracts

The U.K. Finance Bill 2014, published today, includes provisions aimed at preventing the avoidance of income tax by a small number of non-U.K. domiciled individuals who work under arrangements commonly known as “dual contracts,” as had been previously announced in the Autumn Statement 2013 and the 2014 Budget Statement. Why This Matters Although these... »

UNITED KINGDOM: A Welcome Deadline Extension on Software Compliance for RTI

UNITED KINGDOM: A Welcome Deadline Extension on Software Compliance for RTI

The U.K. tax authority has extended the deadline for employers to update their software and be compliant with the Real Time Information system. When an employee is subject to withholding taxes (“PAYE”) on earnings in the U.K. but is also subject to mandatory withholding in another country, relief for the foreign tax can be... »

SOUTH AFRICA: Tax proposals in 2014 budget

SOUTH AFRICA: Tax proposals in 2014 budget

South African Finance Minister Pravin Gordhan delivered his 2014 Budget Speech on 26 February 2014. Among the general corporate tax proposals in the budget are measures to: Limit interest deductions for reorganizations and acquisitions Address the refund mechanism for non-cash dividends Provide changes to research and development (R&D) tax incentives Provide tax relief with... »

ITALY: 20% Withholding on Transfers from Foreign Banks Suspended

ITALY: 20% Withholding on Transfers from Foreign Banks Suspended

A 19 February 2014 communication from the Italian Finance Ministry publicly announced an immediate suspension of the 20-percent withholding tax to be applied by Italian Intermediaries on funds received in Italy by tax resident individuals from foreign bank accounts. A subsequently issued provision by the Tax Agency provides that the 20-percent withholding has not... »

SWITZERLAND: Voters Approve New Immigration Restrictions

SWITZERLAND: Voters Approve New Immigration Restrictions

With a narrow majority of 50.3 percent, Swiss voters decided to add a new article to the Federal Constitution that re-introduces immigration quotas in regard to all types and categories of Swiss residence and work permits. According to a 9 February 2014 press release from the Swiss Federal Council, on 9 February 2014, Swiss... »

ROMANIA: Updated Rules Governing Deductibility of Social Contributions

ROMANIA: Updated Rules Governing Deductibility of Social Contributions

Romania’s Fiscal Code has been updated such that monthly mandatory social security contributions due in other states and paid by taxpayers subject to Romanian taxation, according to European Union (EU) regulations or bilateral conventions / agreements on the coordination of social security systems, are considered deductible for Romanian income tax purposes (previously this was... »

UNITED STATES: Deadline Coming Up for H-1B Visa Petitions for 2015

UNITED STATES: Deadline Coming Up for H-1B Visa Petitions for 2015

Employers that engage foreign workers coming into the United States on H1-B visas are reminded of the rapidly approaching April 1, 2014 “deadline” for the filing of H-1B visa petitions for Fiscal Year 2015. Petitions for the new fiscal year, which starts on October 1, 2014, will be accepted by the government beginning April... »

CANADA: Tax provisions in 2014 federal budget; BEPS consultation

CANADA: Tax provisions in 2014 federal budget; BEPS consultation

February 11: Canada’s Finance Minister today delivered the government’s 2014 federal budget. The budget is focused on job creation, innovation, and infrastructure, and includes a number of tax measures aimed at “closing tax loopholes” in line with the government’s continued focus on tax fairness measures and tax transparency. Tax measures are focused on all... »

UNITED KINGDOM: Details Published on Preventing Use of Dual Contract Arrangements

UNITED KINGDOM: Details Published on Preventing Use of Dual Contract Arrangements

The United Kingdom is implementing new rules that will make it more difficult to use “dual contract” arrangements to lower the U.K. income tax liability of certain foreign nationals. Last week, HM Treasury and HM Revenue & Customs (HMRC) published draft legislation and a paper summarizing the changes to existing legislation in this area.... »

EUROPEAN UNION: New Social Security Practical Guidance Issued

EUROPEAN UNION: New Social Security Practical Guidance Issued

On 13 January 2014, the European Commission published a practical guide1 on the ‘Habitual Residence Test’ to help European Union (EU) member states2 apply EU rules on the coordination of social security. Why This Matters This guidance brings useful clarity for employers with assignees and mobile employees connected to countries party to the provisions... »

IRELAND: Deadline Approaching for 2013 Share Scheme Reporting

IRELAND: Deadline Approaching for 2013 Share Scheme Reporting

In Ireland, the mandatory due date for filing Returns of Information for employee share participation schemes is approaching. This is particularly important for companies where employees and directors have been granted share options, or options have been assigned, released, or exercised by employees and directors, or a Revenue approved share participation scheme has been... »

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... »

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