How To Get A Double Tax Credit From The U.S. To A Tax Credit In An International Treaty
|
|
- Joy Moody
- 3 years ago
- Views:
Transcription
1 Volume 71, Number 6 August 5, 2013 Israeli Tax Reform and U.S. Trusts: Effective Treaty Relief From Double Taxation? by Elizabeth Kessenides Reprinted from Tax Notes Int l, August 5, 2013, p. 561
2 Israeli Tax Reform and U.S. Trusts: Effective Treaty Relief From Double Taxation? by Elizabeth Kessenides Elizabeth Kessenides is a tax attorney with Berdon LLP in New York. The author would like to thank Marc Ausfresser, Robert Cassanos, and Stephen Land for their thoughtful comments and exchanges on the topic of double tax and treaty rules. Most tax practitioners generally believe that when it comes to double taxation risk, tax treaties get you to the right result; that is, either the foreign taxing jurisdiction has to desist, or the United States will grant its citizens/resident taxpayers a credit for the taxes it allows a foreign government to impose under the treaty. This belief is not necessarily well founded, because many treaties currently in force fall short of offering relief from double taxation in all cases. This issue is of the moment, as Israel s government has adopted major reforms to the tax treatment of foreign (that is, non-israeli) trusts. 1 (Related coverage: p. 514.) Until now, Israel did not tax trusts whose settlors were all nonresidents of Israel on foreign-source income. Under the recently passed Israeli legislation (Israeli tax reform), for any trust with beneficiaries that are Israeli residents, either: 1 This article is in response to the summary of the legislative proposals as set forth in Guy Katz, Government Considering Wide-Ranging Tax Reform, Tax Notes Int l, July 1, 2013, p. 40; and Leon Harris, Your Taxes: Trust Proposals Too Bad to Be True, The Jerusalem Post, June 11, The provisions were passed into law in Israel on July 30, the trust itself will be required to pay Israeli income tax; or the beneficiaries who reside in Israel will be subjected to Israeli income tax on distributions. These taxes will apply to Israeli- and foreign-source income. 2 This means that a U.S. trust with beneficiaries who are dual Israel-U.S. residents (including U.S. citizens who are residents of Israel) could face Israeli income tax at a rate of at least 25 percent, or else the Israeli resident beneficiaries will incur Israeli tax on distributions at a rate of 30 percent. Also, there will be U.S. tax imposed on either the trust, the beneficiaries, or (in the case of an entity classified as a grantor trust 3 ) the 2 Id. The bill has been described as setting forth different regimes for cases in which the settlor of the trust is still living, as opposed to trusts that exist after the death of the settlor; there are also distinctions made for trusts with a defined class of relatives as the only beneficiaries. In some cases, the trust will be liable to tax in Israel, and in other cases distributions to beneficiaries will be taxed, with a possible irrevocable election available to the trust (to incur tax at the trust level). 3 Under the grantor trust provisions of the Internal Revenue Code of 1986 as amended, the grantor is treated as the owner of the trust s assets and is taxed directly on its income. See sections of the code. All section references herein are to the code, unless otherwise indicated. TAX NOTES INTERNATIONAL AUGUST 5,
3 FEATURED PERSPECTIVES grantor. 4 Large numbers of trusts exist that have been established by U.S. citizen grantors, with beneficiaries who are both U.S. citizens and residents of Israel. How will the Israeli tax reform affect such trusts? The potential for double taxation and the application of the Israel-U.S. tax treaty 5 to avoid this result raises interesting questions of treaty interpretation. It appears that in cases where the trust itself is the relevant taxpayer in both countries, the treaty should offer some relief by requiring Israel to offer a tax credit for certain U.S. taxes incurred by the U.S. trust, 6 and the United States to offer a credit for certain taxes imposed by Israel. But where the trust is the relevant taxpayer in one jurisdiction, and either the beneficiaries or the grantor are the relevant taxpayers in the other jurisdiction, the answers are unsettled. The discussion below reviews the application of U.S. domestic law to a U.S. trust that is potentially subject to Israeli tax under the bill, the relevant provisions of the treaty, and the unanswered questions that remain. For this discussion, it has been assumed that the assets of the trust consist solely of stock and securities, and that any such stock does not represent an interest in a United States real property holding corporation. 7 Background 4 The proposals in Israel apply to trusts regardless of whether they are classified from a U.S. tax standpoint as grantor trusts, testamentary trusts, or simple or complex trusts. 5 See Convention Between the Government of the United States of America and the Government of the State of Israel With Respect to Taxes on Income, signed Nov. 20, 1975; Protocol Amending the Convention Between the Government of the United States of America and the Government of the State of Israel With Respect to Taxes on Income, signed May 30, 1980; and Second Protocol Amending the Convention Between the Government of the United States of America and the Government of the State of Israel With Respect to Taxes, signed Jan. 26, For purposes of this article, the term U.S. trust refers to a trust that is a U.S. resident under the provisions of section 7701(a)(30). 7 The term United States real property holding corporation is defined in section 897(c)(2). 8 Section 904(a) and 904(b). In the absence of a treaty granting appropriate relief from double taxation, a U.S. taxpayer can seek some relief by virtue of claiming, to the extent allowable under the Internal Revenue Code, a foreign tax credit. U.S. statutory law imposes limitations on a taxpayer s opportunity to claim a foreign tax credit, however. The provisions of section 904 limit the foreign credit that can be claimed to the U.S. tax on income from foreign sources. 8 Thus, if the income on which the foreign tax is paid is treated as U.S.-source income under the code, without a relevant treaty that would re-source the income to make it foreign-source income, it is possible that no relief will be available in the United States for foreign taxes paid. It may be the rare case in which a foreign country imposes tax on income treated as U.S. source under U.S. statutory rules, but the situation can (and does) arise from time to time, particularly with intangible assets. For example, many foreign countries tax sales of stock by nonresidents where the stock represents an interest in an entity whose value is derived principally from real estate located in that foreign country. Gain on such a sale would, in the hands of a U.S. resident, be treated as U.S.-source income under section 865, which sets forth statutory source rules for income relating to sales of non-inventory personal property. The section 865 source rules were dramatically altered by Congress in Until that time, gain on personal property sales was sourced by reference to the location of the sale, generally understood to be a title passage rule. 9 This approach was susceptible to manipulation, and when tax rates were reduced in 1986, Congress decided to change the determination to a residence-based standard. 10 Thus, in the case of a U.S. resident, income or gain from the sale of personal property is generally U.S. source; in the case of a nonresident, the income or gain is generally non-u.s. source. 11 (There are some exceptions to this basic residence rule, including one that requires in the case of a U.S. citizen residing abroad that a foreign tax of 10 percent or more be incurred on the income, otherwise the income is treated as U.S. source.) 12 In terms of double tax conventions, because the United States taxes its citizens as well as its residents on their worldwide income, the U.S. generally insists on the inclusion of a savings clause the effect of which is to preserve the right of the U.S. to tax citizens and residents on the basis of the provisions contained in the code. The Israel-U.S. treaty s savings clause (article 6(3)) reads as follows: Notwithstanding any provisions of this Convention except paragraph (4), a Contracting State may tax its residents and its citizens as if this Convention had not come into effect. Article 6(4) provides, in relevant part, that the provisions of article 6(3) shall not affect the benefits conferred under article 26. Thus, the savings clause of the treaty does not override article See Staff of the Joint Committee on Taxation, General Explanation of the Tax Reform Act of 1986, pp Id. 11 Section 865(a). Before section 865(a) was adopted in 1986, the source of income from gains of sales of personal property depended on the place of sale. See Boris Bittker and Lawrence Lokken, Federal Taxation of Income, Estates & Gifts, para The place of sale rule, however, was acknowledged as being susceptible to manipulation. 12 Section 865(g). 562 AUGUST 5, 2013 TAX NOTES INTERNATIONAL
4 Article 26 is titled Relief from Double Taxation ; it thus conveys the general goal of the treaty, even though it may not always assure this result. Article 26(1) of the Israel-U.S. treaty provides: In accordance with the provisions and subject to the limitations of the law of the United States (as it may be amended from time to time without changing the general principle hereof), the United States shall allow a citizen or resident of the United States as a credit against the United States tax the appropriate amount of taxes paid or accrued to Israel. The lead-in language to the provision quoted above is very meaningful it reinforces the concept that while a credit may be allowed, it is subject to the limitations of the law of the United States. These limitations include, under current law, the limitation imposed by section 904 referred to above. Israel similarly has agreed in article 26(3) of the treaty to allow to a resident of Israel a credit for U.S. taxes paid in accordance with and subject to the limitations of Israeli law. 13 The subject to modifier was added in 1993 by the second protocol. The U.S. Treasury Department explanation of the second protocol, in addressing this new modifier, stated as follows: However, the law as it is applied [by Israel] at any time must be consistent with the general provisions of the paragraph, i.e., it must continue to provide for a full foreign tax credit for U.S. income tax. 14 The treaty also contains source rules. Article 4 (source of income) addresses the sale of tangible or intangible personal property. When the treaty was first adopted, article 4 required that such income shall be treated as income from sources within a Contracting State only if such sale, exchange or other disposition is within that Contracting State. 15 Thus, the Israel-U.S. treaty adopted a situs test, presumably a title passage rule, for determining source. 16 When the treaty was adopted in 1975, the source rules under section The subject to concept, in terms of Israel s tax credit being subject to the provisions of law in Israel, was inserted into the treaty by the second protocol in See U.S. Treasury Department, Technical Explanation of the Second Protocol. 15 Article 4(6) also includes a special source rule for sales of stock in some Israeli corporations, but that rule is not the focus of this article, which instead focuses on sales of publicly traded securities or stock of U.S. domestic corporations. 16 The Treasury Department technical explanation of the treaty, as amended by the first protocol, acknowledged that the source rules of article 4 may differ from those provided in the code, and went on to state that a taxpayer may not make inconsistent choices between Code and Convention rules. See Technical Explanation of the Convention Between the Government of the United States of America and the Government of the State of Israel, May 30, FEATURED PERSPECTIVES also applied a title passage rule for sourcing income from sales of personal property. Congress amended the law in 1986 because it considered the test too easily susceptible to manipulation. 17 Under a title passage rule, title generally passes, in the case of exchangelisted securities, under the rules of the relevant clearing system. The question thus becomes, What is the relationship between the code provisions and the treaty? Which rule is given preference? While Congress can override the provisions of a double tax convention, particularly if Congress makes clear its intent to do so, in the case of Israel, the second protocol was agreed to by the U.S. and Israeli governments in 1993; thus, it was accepted by the United States a number of years after the revisions to section 865. In the second protocol, specific reference was made to the source rules of article 4 and their application to sales of some intangible assets in computing the foreign tax credit. Article 26(4) now provides: Notwithstanding any other provision of this Convention, the source rule for income derived from the sale, exchange or other disposition of stock or of interests in an intangible set forth in Article 4 shall apply for purposes of this Article. The other source rules set forth in Article 4 shall also apply for purposes of this Article, to the extent not prohibited by the domestic law of the Contracting State that is providing relief from double taxation. Further, the U.S. Treasury Department explanation of the 1993 second protocol specifically states that it is intended that this rule apply notwithstanding the savings clause of Art. 6. This appears to make clear the decision of the competent authorities at that time regarding the manner in which source would be determined, and it should prove helpful when dealing with sales of personal property and the potential for double taxation. If a person is entitled to claim treaty benefits, that person should be entitled to claim a tax credit, in Israel, for U.S. tax paid on U.S.-source income (as determined under the treaty). What About Dual Residents? Article 3 of the Israel-U.S. treaty defines fiscal residence. Under article 3 of the treaty, a trust with a grantor who is a U.S. person and dual-resident beneficiaries could be classified as both a U.S. resident and an Israeli resident trust. While there are tie-breaker rules in the treaty for natural persons, the treaty does not currently provide a tie-breaker rule for entities. Article 3(3), added in 1993 by the second protocol, reads: 17 The rule clearly allowed for selectivity on the part of taxpayers. See Rev. Rul , C.B. 287, in which an exchange of debentures for stock was sourced based on where the exchange agent to whom the debenture-holder surrendered its certificates was located (and the holder could freely choose). TAX NOTES INTERNATIONAL AUGUST 5,
5 FEATURED PERSPECTIVES where a person other than an individual is a resident of both Contracting States, the competent authorities of the Contracting States shall endeavor to settle the question by mutual agreement and determine the mode of application of the Convention to such person. Until the competent authorities make such a determination, the person shall not be treated as a resident of either Contracting State except for purposes of Article 26 (Relief from Double Taxation), Article 27 (Nondiscrimination) and Article 31 (Entry into Force). Thus, a dual-resident trust is not able to assert the benefits of the treaty generally until the competent authorities act (for example, for purposes of reduced rates of withholding on dividends, or interest). But the dual resident trust should be able to assert treaty benefits for purposes of the relief from double tax section provided for by article 26 even absent action by the competent authorities, and the source rules of article 4 are specifically referenced in article 26. Who Will Offer the Credit? Where does this leave a trust treated as a U.S. person under the code, if one or more of its beneficiaries are dual residents? Would the provisions of article 26 compel Israel to issue a credit for U.S. taxes paid by a U.S. trust? What if the tax in the United States is paid not by the trust but by the grantor? What if the tax in Israel is paid by the resident beneficiaries? The most straightforward situation is one in which the tax is paid, in both countries, at the trust level. Let s assume for this purpose that all income earned by the trust would be sourced to the United States under the treaty source rules, either because of the situs of sale test or because the payer of the relevant income (dividends or interest) is in the United States. 18 If Israeli income tax is imposed on income sourced to the United States, Israel should allow the trust to claim a tax credit for U.S. taxes paid by the trust. The United States would not, in such instance, allow a tax credit (assuming the trust did not have other nontaxed sources of foreign income), because all the trust s income would be U.S. source (implicating the foreign tax credit limitation rules of section 904, which are emphasized by the lead-in language in accordance with and subject to the limitations of U.S. law ). Matters become uncertain, however, for trusts taxed as grantor trusts under the provisions of the code. In those cases, the relevant taxpayer in the United States 18 Article 4 of the treaty provides that dividend income shall be sourced as income from within a contracting state only if paid by a corporation of that state. Interest income is treated as income from within a contracting state if paid by the relevant country, a political subdivision thereof, or a resident of the contracting state. is the individual grantor whereas the relevant taxpayer in Israel will be either the trust itself or the beneficiaries. In fact, because the Israeli tax reform appears to impose tax in situations in which a trust has beneficiaries who are Israeli residents as well as other beneficiaries who are not, the more likely outcome is that the beneficiaries will incur tax in Israel on the distributions. 19 If so, a proper offset would not appear to be possible, unless the competent authorities reach some sort of agreement allowing for a credit to be claimed even if the tax was imposed, in the other country, on a different taxpayer. 20 To illustrate the point, consider the situation in which a U.S. citizen and resident is the grantor of a grantor trust, established for the benefit of his grandchildren. Some of the grandchildren are residents of Israel. Assume the trust s income, both under the treaty s sourcing rules (as well as U.S. statutory rules), is all U.S. source. In the United States, the relevant taxpayer is the grantor, who is required to include the income earned by the trust on her return. In Israel, the relevant taxpayer is the trust. Under article 26(3) of the treaty, Israel is only required to offer a foreign tax credit to a resident of Israel for the amount of taxes that resident paid: Israel shall allow to a resident of Israel as a credit against Israeli tax the appropriate amount of income taxes paid or accrued to the United States...Such appropriate amount shall be based upon the amount of tax paid or accrued to the United States but shall not exceed that portion of Israeli tax which such resident s net income from sources within the United States bears to his entire net income for the same taxable year. There is nothing in the treaty requiring Israel to recognize taxes paid by the grantor as taxes paid by the trust, though that would seem to be the proper result. Thus, it is not clear at this time that any offset would be available. 19 In the case of a trust with both Israeli resident and U.S. resident beneficiaries, the trustee may decide that it is not appropriate for the trust to pay tax on its income, which may or may not ultimately be distributed to the Israeli resident beneficiaries. Thus, while the tax rate imposed at the beneficiary level in Israel is proposed to be higher (30 percent as opposed to 25 percent), there may be other considerations that result in tax being paid at the beneficiary level. 20 It is worth observing that in a mirror image situation, if the United States were to impose tax on beneficiaries who received distributions from a trust treated as a grantor trust under Israeli tax law, the code offers some relief section 667(d)(1) appears to offer a foreign tax credit and the provisions of section 665 would allow relief even if it was the settlor who paid the tax in Israel. This example lends further support to the view that Israel should take into account taxes paid by U.S. grantors and offer appropriate relief where the grantor is paying tax to the United States. 564 AUGUST 5, 2013 TAX NOTES INTERNATIONAL
6 Given this dilemma, the U.S. grantor might decide to take steps to source the income earned by the trust to Israel (while this would not be within her control in the case of interest and dividend income, it could work for some personal property sales). Such measures might allow some foreign tax credit to be claimed in the United States. But even this approach is likely to mean a real tax increase. Israel s tax rate is higher than the maximum U.S. tax rate applicable to long-term capital gains. Furthermore, beginning this year, in the U.S. there is a 3.8 percent additional tax that would apply under section 1411, a tax that may not necessarily be offset by foreign tax credits. 21 To take the hypothetical further, when a grantor of a U.S. grantor trust is a U.S. citizen but is an Israeli 21 As section 1411 is drafted, foreign taxes would not appear to be creditable in computing net investment income. See New York State Bar Association Report on the Proposed Regulations Under Section 1411 (May 15, 2013). This NYSBA report discusses the possible implications when a taxpayer incurs foreign tax on net investment income, including arguments in favor of treating the section 1411 tax as a tax for foreign tax credit limitation purposes under section 905. The report also raises the question whether Congress intended to override treaty provisions when adopting this provision. FEATURED PERSPECTIVES resident with a tax home in Israel, under the source rules of section 865, gain on the sale of stock should be treated as foreign-source income. This may make it easier for a grantor to claim a tax credit (in the case of an entity taxed as a grantor trust) for the Israeli tax paid, if the tax is paid by the trust itself. The treaty rules for determining the source of income suggest that sales of stock might be structured to best suit the needs of a taxpayer. This is precisely the sort of thing Congress sought to avoid when it adopted the changes to section 865. A great deal remains to be seen about how Israel will implement the provisions of the recently enacted law particularly as it relates to trusts that are also residents of other countries. Trustees would be well advised to seek guidance on this topic, and tax advisers will have to parse through the treaty with different factual variations in mind. The latest reports indicate that the provisions of the Israeli tax reform affecting trusts will become effective on January 1, It is possible that until the competent authorities act, double taxation cannot be ruled out in all instances. TAX NOTES INTERNATIONAL AUGUST 5,
DEPARTMENT OF THE TREASURY TECHNICAL EXPLANATION OF THE PROTOCOL BETWEEN THE UNITED STATES OF AMERICA AND
DEPARTMENT OF THE TREASURY TECHNICAL EXPLANATION OF THE PROTOCOL BETWEEN THE UNITED STATES OF AMERICA AND THE FRENCH REPUBLIC SIGNED AT WASHINGTON ON DECEMBER 8, 2004 AMENDING THE CONVENTION BETWEEN THE
More informationArticle 1. Paragraph 3 of Article IV Dual resident companies
DEPARTMENT OF THE TREASURY TECHNICAL EXPLANATION OF THE PROTOCOL DONE AT CHELSEA ON SEPTEMBER 21, 2007 AMENDING THE CONVENTION BETWEEN THE UNITED STATES OF AMERICA AND CANADA WITH RESPECT TO TAXES ON INCOME
More informationYour Taxes: IRS grants 3-week extension for its tax-amnesty program
Your Taxes: IRS grants 3-week extension for its tax-amnesty program Sep. 22, 2009 KEVIN E. PACKMAN and LEON HARRIS, THE JERUSALEM POST This article is an urgent update for US taxpayers... and it comes
More informationTREASURY DEPARTMENT TECHNICAL EXPLANATION OF THE PROTOCOL BETWEEN THE UNITED STATES OF AMERICA AND
TREASURY DEPARTMENT TECHNICAL EXPLANATION OF THE PROTOCOL BETWEEN THE UNITED STATES OF AMERICA AND THE FEDERAL REPUBLIC OF GERMANY SIGNED AT WASHINGTON ON DECEMBER 14, 1998 AMENDING THE CONVENTION BETWEEN
More informationImmigrating to the USA: effective wealth planning Charles P LeBeau, Attorney, San Diego, California, USA
Immigrating to the USA: effective wealth planning Charles P LeBeau, Attorney, San Diego, California, USA Although considerations will vary widely depending on the circumstances of the specific non-resident
More informationQualified Plans in Puerto Rico
ARTICLE Qualified Plans in Puerto Rico By Elizabeth A. LaCombe In this article, Elizabeth A. LaCombe discusses some practical issues that a U.S. employer should consider before offering retirement benefits
More informationIncome in the Netherlands is categorised into boxes. The above table relates to Box 1 income.
Worldwide personal tax guide 2013 2014 The Netherlands Local information Tax Authority Website Tax Year Tax Return due date Is joint filing possible Are tax return extensions possible Belastingdienst www.belastingdienst.nl
More information'PRIVATE' SPLIT-DOLLAR PROVIDES TRANSFER TAX SAVINGS
Checkpoint Contents Federal Library Federal Editorial Materials WG&L Journals Practical Tax Strategies/Taxation for Accountants (WG&L) Taxation for Accountants 1998 Volume 61, Number 4, October 1998 Articles
More informationTax Effective Cross-Border Will Planning
Tax Effective Cross-Border Will Planning Martin Rochwerg Partner Federated Press Cross-Border Personal Tax Planning February 27-28, 2012 DISCLAIMER 1. We are not U.S. lawyers or tax advisors. 2. This presentation
More informationIRAs as Shareholders in Subchapter S Corporations Who Is An Individual?
IRAs as Shareholders in Subchapter S Corporations Who Is An Individual? 2321 N. Loop Drive, Ste 200 Ames, Iowa 50010 www.calt.iastate.edu October 1, 2009 by Roger A. McEowen* Updated on March 26, 2012
More informationUS Estate Tax for Canadians
US Estate Tax for Canadians RRSPs, RRIFs and TFSAs). The most common US situs assets are US real estate (e.g. vacation home) and shares in US corporations. Please see Appendix A for a list of other common
More informationCOMMENTARIES ON THE ARTICLES OF THE MODEL TAX CONVENTION
COMMENTARIES ON THE ARTICLES OF THE MODEL TAX CONVENTION COMMENTARY ON ARTICLE 1 CONCERNING THE PERSONS COVERED BY THE CONVENTION 1. Whereas the earliest conventions in general were applicable to citizens
More informationTHE IMPORTANCE OF INTERNATIONAL TAX AND ESTATE PLANNING By: Avi Z. Kestenbaum and K. Eli Akhavan
THE IMPORTANCE OF INTERNATIONAL TAX AND ESTATE PLANNING By: Avi Z. Kestenbaum and K. Eli Akhavan The current global economic environment demands that legal, accounting and financial professionals be well
More informationIn a nutshell... Article published in Issue 15, 2009-10 of The Taxpayer, dated 15 Feb 2010. ...the full article follows
Article published in Issue 15, 2009-10 of The Taxpayer, dated 15 Feb 2010 In a nutshell... Going overseas? Coming home? The tax implications So many Australians leave to take up long-term or even permanent
More informationDEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE WASHINGTON, D.C. 20224
DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE WASHINGTON, D.C. 20224 OFFICE OF CHIEF COUNSEL Number: 200215053 Release Date: 4/12/2002 UIL: 3121.04-00 CC:TEGE:EOEG:ET1 WTA-N-115133-01 MEMORANDUM
More informationA 5.5% solidarity surcharge is imposed on the income tax liability of all taxpayers.
Worldwide personal tax guide 2013 2014 Germany Local information Tax Authority Website Tax Year Tax Return due date 31 May 2013 Is joint filing possible Are tax return extensions possible 2013 income tax
More informationto taxation Australian 2005, and The discussions below
General Tax Information Relating to Holdings in Cadbury plc and Cadbury Schweppes plc This discussion of Australian, UK and US tax law considerations is intended only as a descriptive summary and does
More informationSeries LLC Is It Finally Usable?
Originally published in: BNA Tax Management Real Estate Journal November 3, 2010 Series LLC Is It Finally Usable? By: Howard J. Levine and Daniel W. Stahl 1 BACKGROUND Many in the real estate development
More informationTop 10 Tax Considerations for U.S. Citizens Living in Canada
Top 10 Tax Considerations for U.S. Citizens Living in Canada Recent Canadian media reports have estimated that there are approximately one million U.S. citizens living in Canada and that a relatively low
More informationUS estate and gift tax rules for resident and nonresident aliens
US estate and gift tax rules for resident and nonresident aliens Content Non-US citizens may be subject to US estate and gift taxation. If you fit into this category, do you understand the potential tax
More informationU.S.A. Chapter I. Scope of the Convention
U.S.A. Convention between the Kingdom of the Netherlands and the United States of America for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income Done
More informationapplication and interpretation of the Convention. References in the Technical Explanation to he or his should be read to mean he or she or his or her.
DEPARTMENT OF THE TREASURY TECHNICAL EXPLANATION OF THE CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA AND THE GOVERNMENT OF THE UNITED KINGDOM OF GREAT BRITAIN AND NORTHERN IRELAND
More informationRecent developments regarding Mexico s tax treaty network and relevant court precedents
Recent developments regarding Mexico s tax treaty network and relevant court precedents Mexico has a relatively short background on the negotiation and application of treaties for the avoidance of double
More informationHaving amended the Convention by an Additional Protocol that Modifies the Convention, signed at Mexico City on September 8, 1994;
SECOND ADDITIONAL PROTOCOL THAT MODIFIES THE CONVENTION BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA AND THE GOVERNMENT OF THE UNITED MEXICAN STATES FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE
More informationFEDERAL TAXATION OF INTERNATIONAL TRANSACTIONS
Chapter 10 FEDERAL TAXATION OF INTERNATIONAL TRANSACTIONS Daniel Cassidy 1 10.1 INTRODUCTION Foreign companies with U.S. business transactions face various layers of taxation. These include income, sales,
More informationTAX PRESENTATION. By Ronald R. Fieldstone, Esq. and Rebecca Abrams Sarelson, Esq. Arnstein & Lehr LLP
TAX PRESENTATION By Ronald R. Fieldstone, Esq. and Rebecca Abrams Sarelson, Esq. Arnstein & Lehr LLP 1 Table of Contents 1. Immigration Tax and EB-5 5 Planning (a) (b) (c) (d) (e) (f) Pre-departure planning
More informationLara A. Banjanin Attorney-Advisor IRS Office of Associate Chief Counsel (International) 1111 Constitution Avenue NW Washington, DC 20224
[Type text] Lara A. Banjanin Attorney-Advisor IRS Office of Associate Chief Counsel (International) 1111 Constitution Avenue NW Washington, DC 20224 Via Email: lara.a.banjanin@irscounsel.treas.gov Dear
More informationRevocable Trusts WHAT IS A REVOCABLE TRUST?
Revocable Trusts The Revocable Trust (often referred to as a Living Trust ) is a popular and effective estate planning technique used throughout the United States. Its advantages (and disadvantages) should
More informationIs It a Grantor Chartable Lead Trust or Not - How the Grantor Trust Rules Interact with the Charitable Lead Trust, 30 J. Marshall L. Rev.
The John Marshall Law Review Volume 30 Issue 4 Article 7 Summer 1997 Is It a Grantor Chartable Lead Trust or Not - How the Grantor Trust Rules Interact with the Charitable Lead Trust, 30 J. Marshall L.
More informationAt the time of the 2001 terrorist attacks, the future of employer-sponsored
American Bar Association, Section of Taxation Fall Meeting 2011 Tax Issues Affecting Disaster Relief Megan Bell, Patterson Belknap Webb & Tyler LLP David Shevlin, Simpson Thacher & Bartlett LLP Carolyn
More informationWealth Planning Summary of U.S. Income, Estate and Gift Taxation for Non-Resident Aliens
Wealth Planning Summary of U.S. Income, Estate and Gift Taxation for Non-Resident Aliens Overview The United States ( U.S. ) continues to offer attractive investment options to foreign individuals. While
More information26 CFR 601.201: Rulings and determination letters. (Also: Part I, 170, 642(c), 2055, 2522; 1.170A-6, 20.2055-2, 25.2522(c)-3)
Part III Administrative, Procedural, and Miscellaneous 26 CFR 601.201: Rulings and determination letters. (Also: Part I, 170, 642(c), 2055, 2522; 1.170A-6, 20.2055-2, 25.2522(c)-3) Rev. Proc. 2007-45 SECTION
More informationFIRSTSERVICE CORPORATION NOTICE OF REDEMPTION & CONVERSION TO ALL REGISTERED HOLDERS OF OUTSTANDING 7% CUMULATIVE PREFERENCE SHARES, SERIES 1
FIRSTSERVICE CORPORATION NOTICE OF REDEMPTION & CONVERSION TO ALL REGISTERED HOLDERS OF OUTSTANDING 7% CUMULATIVE PREFERENCE SHARES, SERIES 1 To: All Registered Holders of Outstanding 7% Cumulative Preference
More informationTAX DEVELOPMENTS IN POLAND UPDATE 2009
TAX DEVELOPMENTS IN POLAND UPDATE 2009 WARDYŃSKI & PARTNERS TAX PRACTICE APRIL 2010 1/8 INTRODUCTION The purpose of this report is to present key tax developments in Poland in 2009 which may be relevant
More informationACT : INCOME TAX ACT NO. 58 OF 1962 SECTION : SECTION 1(1) SUBJECT : RESIDENT: DEFINITION IN RELATION TO A NATURAL PERSON PHYSICAL PRESENCE TEST
INTERPRETATION NOTE: NO. 4 (Issue 4) DATE: 12 March 2014 ACT : INCOME TAX ACT NO. 58 OF 1962 SECTION : SECTION 1(1) SUBJECT : RESIDENT: DEFINITION IN RELATION TO A NATURAL PERSON PHYSICAL PRESENCE TEST
More informationTax and Estate Planning Issues for Canadian Citizens and Residents residing in the U.S. and Dual U.S.- Canadian Citizens
September 23, 2008 Tax and Estate Planning Issues for Canadian Citizens and Residents residing in the U.S. and Dual U.S.- Canadian Citizens Natalia Yegorova is an associate at Black Helterline LLP. Her
More informationECJ Finds Finnish Withholding Tax Rules Unacceptable in Luxembourg SICAV Case
Volume 55, Number 4 July 27, 2009 ECJ Finds Finnish Withholding Tax Rules Unacceptable in Luxembourg SICAV Case by Tom O Shea Reprinted from Tax Notes Int l, July 27, 2009, p. 305 ECJ Finds Finnish Withholding
More informationDESCRIPTION OF THE PLAN
DESCRIPTION OF THE PLAN PURPOSE 1. What is the purpose of the Plan? The purpose of the Plan is to provide eligible record owners of common stock of the Company with a simple and convenient means of investing
More informationTAXATION OF FOREIGN INCOME ISRAELI RESIDENTS
TAXATION FOREIGN INCOME FELDMAN BRODY & Associates January 2010 No part of this publication may be reproduced without permission Website: www.feldmanbrody.com While every effort has been made to ensure
More informationTO: OUR FRIENDS AND PROSPECTIVE CLIENTS FROM: THOMAS WILLIAMS, CPA RE: U.S. INCOME TAX ISSUES OF FOREIGN NATIONALS DATE: AS OF JANUARY 1, 2010
THOMAS WILLIAMS CPA, PLLC TO: OUR FRIENDS AND PROSPECTIVE CLIENTS FROM: THOMAS WILLIAMS, CPA RE: U.S. INCOME TAX ISSUES OF FOREIGN NATIONALS DATE: AS OF JANUARY 1, 2010 Dear Friends: The following is an
More informationEllen Harrison. Philadelphia Estate Planning Council ( PEPC ) October 21, 2014
Ellen Harrison Philadelphia Estate Planning Council ( PEPC ) October 21, 2014 Topics to be covered Who and what is foreign under the Code and treaties US taxation of citizens regardless of residency Limited
More informationForeign Investment in Real Property Tax Act 1980 Buyer AND Seller Beware. By R. Scott Jones, Esq.
Foreign Investment in Real Property Tax Act 1980 Buyer AND Seller Beware By R. Scott Jones, Esq. This article summarizes the tax withholding rules imposed on a buyer and his/her agent when purchasing U.S.
More informationSAMPLE MODEL LANGUAGE FOR EDWARD JONES TRUST COMPANY FOR THE USE OF LEGAL COUNSEL ONLY
SAMPLE MODEL LANGUAGE FOR EDWARD JONES TRUST COMPANY FOR THE USE OF LEGAL COUNSEL ONLY This sample model language is provided for the reference of the drafting attorney as an educational and informational
More informationSYLLABUS BASICS OF INTERNATIONAL TAXATION. ! States levy taxes by virtue of their sovereignty
SYLLABUS BASICS OF INTERNATIONAL TAXATION! States levy taxes by virtue of their sovereignty! Tax sovereignty, however, is not unlimited. There must either be a personal or an objective connection between
More informationExpatriation - A Comparison of Tax Issues in the US & UK in an Increasingly Mobile World
Expatriation - A Comparison of Tax Issues in the US & UK in an Increasingly Mobile World Henry Christensen III Jay E. Rivlin www.mwe.com Boston Brussels Chicago Düsseldorf Frankfurt Houston London Los
More informationInternational Tax Developments Inbound Update. By Robert A. Chaves, Esq. Gutter Chaves Josepher Rubin Forman Fleisher P.A.
International Tax Developments Inbound Update By Robert A. Chaves, Esq. Gutter Chaves Josepher Rubin Forman Fleisher P.A. I. Legislative/Statutory Updates A. Suspension of Three Year Assessment Limitation
More informationThe application of this constitutional provision to the various taxes administered by the New York State Tax Department is described below.
New York State Department of Taxation and Finance Taxpayer Services Division Technical Services Bureau New York's Tax Policy Relating to the Taxation of Intangible Personal Property of Nonresidents The
More informationGLOBAL GUIDE TO M&A TAX
Quality tax advice, globally GLOBAL GUIDE TO M&A TAX 2013 EDITION www.taxand.com CYPRUS Cyprus From a Buyer s Perspective 1. What are the main differences among acquisitions made through a share deal versus
More informationCLARIFICATION OF THE MEANING OF BENEFICIAL OWNER IN THE OECD MODEL TAX CONVENTION
ORGANISATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENT CLARIFICATION OF THE MEANING OF BENEFICIAL OWNER IN THE OECD MODEL TAX CONVENTION DISCUSSION DRAFT 29 April 2011 to 15 July 2011 CENTRE FOR TAX POLICY
More informationSecond Regular Session Seventieth General Assembly STATE OF COLORADO INTRODUCED HOUSE SPONSORSHIP SENATE SPONSORSHIP
Second Regular Session Seventieth General Assembly STATE OF COLORADO INTRODUCED LLS NO. 1-01.01 Esther van Mourik x1 HOUSE BILL 1-1 Foote and Pettersen, HOUSE SPONSORSHIP Jones and Donovan, SENATE SPONSORSHIP
More informationBANK OF MONTREAL SHAREHOLDER DIVIDEND REINVESTMENT AND SHARE PURCHASE PLAN
BANK OF MONTREAL SHAREHOLDER DIVIDEND REINVESTMENT AND SHARE PURCHASE PLAN This Offering Circular covers common shares of Bank of Montreal (the Bank ) which may be purchased on the open market through
More informationNORTHERN BLIZZARD RESOURCES INC. STOCK DIVIDEND PROGRAM
NORTHERN BLIZZARD RESOURCES INC. STOCK DIVIDEND PROGRAM Introduction This Stock Dividend Program (the "Program") provides eligible holders ("Shareholders") of common shares ("Common Shares") of Northern
More informationWHAT OHIO LAWYERS NEED TO KNOW ABOUT ESTATE PLANNING FOR CLIENTS DOMICILED IN FLORIDA
WHAT OHIO LAWYERS NEED TO KNOW ABOUT ESTATE PLANNING FOR CLIENTS DOMICILED IN FLORIDA DAVID J. SIMMONS 4690 MUNSON ST., N.W. CANTON, OH 44718 330-499-8899 email: esimmonscleav@neo.rr.com I. FLORIDA DOMICILE
More informationMonaco Corporate Taxation
Introduction Monaco is a sovereign principality. France is a guarantor of the sovereignty and territorial integrity of Monaco, while Monaco is to conform to French interests. Although the Prince is the
More informationCYPRUS TAX CONSIDERATIONS
TAXATION The following summary of material Cyprus, US federal income and United Kingdom tax consequences of ownership of the GDRs is based upon laws, regulations, decrees, rulings, income tax conventions
More informationTax Planning for New Immigrants and Returning Residents
Tax Planning for New Immigrants and Returning Residents Federated Press Seminar November 6, 2013 Presented by: Lorne Saltman Four Levels of Planning Pre-Immigration Planning Immigration Planning Post-Immigration
More informationHolding companies in Ireland
Holding companies in Irel David Lawless Paul Moloney Dillon Eustace, Dublin Irel has long been a destination of choice for holding companies because of its low corporation tax rate of 12.5 percent, participation
More informationTreatment of COD Income by Partnerships
Treatment of COD Income by Partnerships Stafford Presentation January 28, 2015 Polsinelli PC. In California, Polsinelli LLP Allocation of COD Income COD income is allocated to those partners who are partners
More informationTAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS
TAXATION OF INTEREST, DIVIDENDS AND CAPITAL GAINS IN CYPRUS LAWS AND DECREES The Income Tax (Amendment) Law of 2005 The Special Contribution for Defence (Amendment) Law of 2004 The Assessment and Collection
More informationEstate Planning for the International Client
Estate Planning for the International Client Brenda Jackson-Cooper Doug Andre March 24, 2015 I. Rules and Definitions Agenda II. Estate Planning Case Studies III. Questions 2 Effects of U.S. transfer tax
More informationWorldwide personal tax guide 2013 2014. Japan. Local information. 2013 National Income Tax Rates Taxable Income Band National Income Tax Rates
Worldwide personal tax guide 2013 2014 Japan Local information Tax Authority Ministry of Finance Website www.mof.go.jp Tax Year 1 January to 31 December Tax Return due date 15 March Is joint filing possible
More informationCyprus International Trusts
Cyprus International Trusts Cyprus International Trusts qualification criteria The International Trusts Law of 1992 complements the Trustee Law which is based on the English Trustee Act 1925. Under section
More informationScheduled for Markup by the SENATE COMMITTEE ON FINANCE on February 11, 2015. Prepared by the Staff of the JOINT COMMITTEE ON TAXATION
DESCRIPTION OF THE CHAIRMAN S MARK OF PROPOSALS RELATING TO REAL ESTATE INVESTMENT TRUSTS (REITs), REGULATED INVESTMENT COMPANIES (RICs) AND THE FOREIGN INVESTMENT IN REAL PROPERTY TAX ACT (FIRPTA) Scheduled
More informationGerman Tax Facts. The Expatriate Financial Guide to Germany
The Expatriate Financial Guide to Germany German Tax Facts Introduction Tax Year Assessment Basis Income Tax Taxation in Germany occurs at a national and municipal level. The Ministry of Finance controls
More informationIntroduction. Article 1
DEPARTMENT OF THE TREASURY TECHNICAL EXPLANATION OF THE PROTOCOL BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA AND THE GOVERNMENT OF AUSTRALIA SIGNED AT CANBERRA ON SEPTEMBER 27, 2001, AMENDING
More informationDual residents. Helpsheet 302
Helpsheet 302 Tax year 6 April 2013 to 5 April 2014 Dual residents A Contacts Please phone: the number printed on page TR 1 of your tax return the SA Helpline on 0300 200 3310 the SA Orderline on 0300
More informationInternal Revenue Service
Internal Revenue Service Number: 200925003 Release Date: 6/19/2009 Index Number: 2511.00-00, 2042.00-00, 61.09-38 ------------------------- ------------------------- ---------------------------- Department
More informationForeign Nationals in the U.S. Estate Tax, Wills & Guardianship
Foreign Nationals in the U.S. Estate Tax, Wills & Guardianship R. Scott Jones, Esq.* Foreign nationals arriving in the United States as investors or on business generally have a lot on their mind, but
More informationHow Canada Taxes Foreign Income
- 1 - How Canada Taxes Foreign Income (Summary) Purpose of the book The purpose of writing this book, entitled How Canada Taxes Foreign Income is particularly for the benefit of foreign tax lawyers, accountants,
More informationUSA Taxation. 3.1 Taxation of funds. Taxation of regulated investment companies: income tax
USA Taxation FUNDS AND FUND MANAGEMENT 2010 3.1 Taxation of funds Taxation of regulated investment companies: income tax Investment companies in the United States (US) are structured either as openend
More informationSpin-Off of Time Warner Cable Inc. Tax Information Statement As of March 19, 2009
Spin-Off of Time Warner Cable Inc. Tax Information Statement As of March 19, 2009 On March 12, 2009, Time Warner Inc. ( Time Warner ) completed the spin-off (the Spin-Off ) of Time Warner s ownership interest
More informationThe Following pages contain an example of a form that could be used to collect data from entities in relation to the CRS.
February 2016 Guidance for Financial Institutions Requesting the Form The Following pages contain an example of a form that could be used to collect data from entities in relation to the CRS. This form
More informationTax and Succession Planning for Immigration to the United States
Tax and Succession Planning for Immigration to the United States Michael J. Legamaro May 2011 1 Concerns Upon Moving to US Minimizing US income tax Minimizing US estate tax Managing State law considerations
More informationTrust and Estate Planning Considerations When Advising Canadians Living in the United States
This article is reprinted with the publisher's permission from the Journal of Practical Estate Planning, a bimonthly journal published by CCH, INCORPORATED. Copying or distribution without the publisher's
More informationUnited States. A-Z of U.S. Estate Planning Concepts
United States A-Z of U.S. Estate Planning Concepts This glossary is directed mainly at the solicitor whose clients are American, have assets in America, or U.S. family members who are beneficiaries of
More informationPRIVATE CLIENT BRIEFING:
PRIVATE CLIENT BRIEFING: I M A US CITIZEN RESIDENT IN THE UK, WHAT DO I NEED TO KNOW? JANUARY 2013 Almost uniquely, the US taxes its citizens (and Green Card holders) on a worldwide basis regardless of
More informationGENERAL EFFECTIVE DATE UNDER ARTICLE 29: 1 JANUARY 1994 INTRODUCTION TABLE OF ARTICLES
TREASURY DEPARTMENT TECHNICAL EXPLANATION OF THE CONVENTION AND PROTOCOL BETWEEN THE GOVERNMENT OF THE UNITED STATES OF AMERICA AND THE GOVERNMENT OF THE UNITED MEXICAN STATES FOR THE AVOIDANCE OF DOUBLE
More informationWhat s News in Tax Analysis That Matters from Washington National Tax
What s News in Tax Analysis That Matters from Washington National Tax IRS Challenges Property and Casualty Policyholder Dividend Deductions Property and casualty insurance companies are allowed a deduction
More informationCross Border Tax Issues
Cross Border Tax Issues By Reinhold G. Krahn December 2000 This is a general overview of the subject matter and should not be relied upon as legal advice or opinion. For specific legal advice on the information
More informationThe Federal Circuit Affirms a Court of Federal Claims Decision Dismissing Foreign Tax Credit Refund Claims as Untimely
Tax Controversy Services IRS Insights In this issue: The Federal Circuit Affirms a Court of Federal Claims Decision Dismissing Foreign Tax Credit Refund Claims as Untimely... 1 The Court of Federal Claims
More informationPanel. U.S. and Mexican Taxation of Individuals Residing Abroad
Panel U.S. and Mexican Taxation of Individuals Residing Abroad Diana S. Davis, Esq., Of Counsel, Greenberg Traurig, LLP Kenneth Guilfoyle, CPA, Expatriate Services Practice Leader, BDO Seidman, LLP U.S.
More informationU.S. Taxation of Foreign Investors
PART OF THE LEHMAN TAX LAW KNOWLEDGE BASE SERIES United States Taxation Of Investors U.S. Taxation of Foreign Investors Non Resident Alien Individuals & Foreign Corporations By Richard S. Lehman Esq. TAX
More informationMy client s a US citizen resident in the UK, what do I need to know?
My client s a US citizen resident in the UK, what do I need to know? So if my client s estate is worth less than the Credit Amount, my client has no reason to worry? Unfortunately, it isn t that simple.
More informationUSE OF DELAWARE INCOMPLETE GIFT NON-GRANTOR TRUSTS IN LIGHT OF IR-2007-127
USE OF DELAWARE INCOMPLETE GIFT NON-GRANTOR TRUSTS IN LIGHT OF IR-2007-127 Michael M. Gordon, Esquire Gordon, Fournaris & Mammarella, P.A. 1925 Lovering Avenue Wilmington, DE 19806 Tel: (302) 652-2900
More informationMEXICAN TAX BILL FOR 2016
MEXICAN TAX BILL FOR 2016 On September 8, 2015, the President sent to Congress the Tax Bill where some proposals are made to change current Mexican tax legislation. The main proposals are the following:
More informationA PRIMER ON THE HISTORIC REHABILITATION TAX CREDIT
COMBINING HISTORIC PRESERVATION AND BROWNFIELD DEVELOPMENT INCENTIVES AND TAX CREDITS: CASE STUDIES IN CREATIVE DEAL MAKING A PRIMER ON THE HISTORIC REHABILITATION TAX CREDIT John H. Gadon Lane Powell
More informationTAX PLANNING FOR THE FOREIGN REAL ESTATE INVESTOR
TAX PLANNING FOR THE FOREIGN REAL ESTATE INVESTOR Tax Benefits and Tax Traps By Richard S. Lehman & Associates Attorneys at Law TAX PLANNING FOR THE FOREIGN REAL ESTATE INVESTOR Tax Benefits and Tax Traps
More informationSPLITTING CORPORATIONS UNDER SECTION 355
ABA SECTION OF TAXATION / SECTION OF REAL PROPERTY, TRUST & ESTATE LAW JOINT PROGRAM Denver, Colorado October 22, 2011 NEXT GENERATION DISPUTES IN THE FAMILY BUSINESS: NAVIGATING THE REMEDIAL, ETHICAL
More informationtax bulletin State of Play: International Tax Policy in the 111 th Congress www.venable.com AUGUST 2010 By E. Ray Beeman and Samuel Olchyk
tax bulletin www.venable.com AUGUST 2010 State of Play: International Tax Policy in the 111 th Congress By E. Ray Beeman and Samuel Olchyk The 111th Congress will soon return from its summer recess to
More informationMEXICO TAXATION GUIDE
THE FLORES LAW FIRM Attorney and Counselor at Law 9901 IH-10 West, Suite 800 San Antonio, TX 78230 TEL. (210) 340-3800 FAX (210) 340-5200 MEXICO TAXATION GUIDE I. RECOGNIZED MEXICAN BUSINESS ENTITIES A.
More informationMANUAL ON EFFECTIVE MUTUAL AGREEMENT PROCEDURES (MEMAP)
ORGANISATION FOR ECONOMIC CO-OPERATION AND DEVELOPMENT MANUAL ON EFFECTIVE MUTUAL AGREEMENT PROCEDURES (MEMAP) February 2007 Version CENTRE FOR TAX POLICY AND ADMINISTRATION MANUAL ON EFFECTIVE MUTUAL
More informationUNITED STATES - MEXICO INCOME TAX CONVENTION
UNITED STATES - MEXICO INCOME TAX CONVENTION Convention, with Protocol, Signed at Washington on September 18, 1992; Transmitted by the President of the United States of America to the Senate on May 20,
More informationMemorandum. Office of Chief Counsel Internal Revenue Service. Number: 200803016 Release Date: 1/18/2008 CC:PA:B03: POSTS-100069-07 UILC: 6324A.
Office of Chief Counsel Internal Revenue Service Memorandum Number: 200803016 Release Date: 1/18/2008 CC:PA:B03: UILC: 6324A.00-00 date: October 11, 2007 to: Mary P. Hamilton Senior Attorney (Boston) (Small
More informationU.S. Tax Structures Utilized In Connection With Foreign Investment In U.S. Real Estate. Jack Miles Kelley Drye & Warren LLP
U.S. Tax Structures Utilized In Connection With Foreign Investment In U.S. Real Estate Jack Miles Kelley Drye & Warren LLP May 2, 2016 Topics I. Structuring Objectives II. Underlying U.S. Tax Rules --
More informationTax. Pinhas Rubin, Daniel Paserman /29/
Tax Gornitzky & Co. Pinhas Rubin, Daniel Paserman /29/ Trends in Israeli Tax Law Change of a Business Model - International Acquisitions of Israeli Hi-Tech Companies International corporations are extremely
More informationDIVORCE AND LIFE INSURANCE, QUALIFIED PLANS AND IRAS 2013-2015
DIVORCE AND LIFE INSURANCE, QUALIFIED PLANS AND IRAS 2013-2015 I. INTRODUCTION In a divorce, property is generally divided between the spouses. Generally, all assets of the spouses, whether individual,
More informationEXPLANATION OF PROPOSED INCOME TAX TREATY BETWEEN THE UNITED STATES AND HUNGARY
EXPLANATION OF PROPOSED INCOME TAX TREATY BETWEEN THE UNITED STATES AND HUNGARY Scheduled for a Hearing Before the COMMITTEE ON FOREIGN RELATIONS UNITED STATES SENATE On June 7, 2011 Prepared by the Staff
More informationIRREVOCABLE LIVING TRUST
Legal Note: The Documents here are provided for your information and that of your immediate family only. You are not permitted to copy any document provided to you. Each of these Documents provided are
More information