Instead of expatriating, it is better to consider retaining your U.S. citizenship and becoming a resident of Puerto Rico. You sign a 20 year contract with the government. As a result, as an individual, you can pay zero federal and state tax on local interest, dividends and capital gains. The incentives for business are also phenomenal: a 4% rate with profits paid to owners tax free. A business must have 3 employees of which husband and wife can count as two.
Alternative Ways To Protect The ResidenceBruce Givner
This document summarizes different options for protecting a house, including doing nothing, giving the house to children, selling the house to children, contributing the house to a family limited partnership, using a Qualified Personal Residence Trust, Grantor Retained Annuity Trust, or Private Retirement Trust. It outlines the setup requirements, tax implications, ability of creditors to access the house, rental options, ability to deduct debt, and ability to access equity for each option.
14 07-09 orange county bar association - int'l estate planningBruce Givner
U.S. persons with real estate in multiple countries; U.S. persons with relatives in other countries; U.S. citizens abroad; non-U.S. persons with real estate in the U.S.; residency for income tax purposes; residency for transfer tax purposes; expatriation;
Family Limited Partnerships Update - Diagrams and Bullet Points - February 6,...Bruce Givner
Normal FLP structure for estate tax planning; modifying it to amplify the extent to which it can help add a hurdle between valuable assets and some future (not currently in existence) creditor if properly aged (4 - 7 years before there is a problem) and if it has a business purpose; important points in the event of an estate tax audit, e.g., separate counsel for the children's trust; problem of timing of the funding of the assets to the FLP versus timing of the gift of LP interests; problem of the change of California's LLC act effective 1/1/14; use of FLPs with captive insurance companies, pensions, life insurance and as an alternative to an ILIT.
In 1989 Alaska was the first state to allow a domestic asset protection trust. In that same year Nevada and Delaware also changed their laws to allow DAPTs (also called self-settled spendthrift trusts). The question was - for 30 years - if a person in California set up a DAPT in Nevada - could a judgment creditor in California take his judgment to Nevada and have the Nevada court enforce the judgment against the California debtor's asset protection trust. Some lawyers argued "yes," citing Art. IV, Section 1 of the U.S. Constitution, the "full faith and credit clause." Other lawyers argued "No, it would be against Nevada's public policy." Finally, in June, 2019, the South Dakota Supreme Court held that it would give "full faith and credit to the California family law court order. However, it would not give full faith and credit to the enforcement against a South Dakota trust. Will this case make it to the U.S. Supreme Court? What about the on-going divorce of Ed and Marie Borsarge? The Cameron case did not involve an asset protection trust. But certainly South Dakota, Nevada and the other states will rule the same way in a case involving an asset protection trust.
Form 9465-Installment Agreement Requesttaxman taxman
The document is an IRS form for requesting an installment agreement to pay back taxes owed. It provides instructions for taxpayers to set up a monthly payment plan rather than paying their full tax balance immediately. Key details include the monthly payment amount, date each payment will be due, and option to have payments automatically withdrawn from a checking account. The IRS will generally respond within 30 days to approve or deny the request, and set up the installment agreement if approved.
Peter and Harriet were invited to speak at an event hosted by Dentons law firm for Belgium investors interested in expanding their business on U.S. soil.
This document provides an overview of estate planning considerations for individuals with cross-border implications. It discusses U.S. gift and estate tax rules for U.S. citizens and residents as well as non-residents. It also covers generation-skipping transfer tax, pre-immigration planning, planning for permanent non-residents, and departure tax rules for expatriates. Special trusts and foreign holding entities are recommended for managing cross-border tax and asset protection issues.
Realogy Corporation announced amendments to its invitation for commitments of up to $500 million in new second lien term loans. The amendments extended the termination date to December 19th and standardized the consideration required to fund commitments accepted after November 26th at the same levels as earlier commitments. Over $237 million in commitments have already been received, for which Realogy has received over $500 million in existing notes. Commitments and delivered notes can no longer be rescinded or withdrawn.
The document summarizes international tax planning opportunities for individuals moving to or from the United States. It discusses pre-arrival planning strategies like realizing income, undertaking asset transactions, and establishing foreign trusts before becoming a US tax resident. It also covers US taxation of residents and nonresidents, US reporting requirements for foreign accounts/entities, and estate planning techniques.
A comprehensive guide of practical planning solutions for business owners and individuals looking to leave California and maintain good financial standing.
This presentation and these materials are designed to provide information in regard to the subject matter
covered. This presentation and these materials are provided solely as a teaching tool, with the
understanding that Stephen Moskowitz, Moskowitz LLP, and the instructor are not engaged in rendering
legal, accounting, or other professional service and that they are not offering such advice in this
presentation and these accompanying materials.
2008 Connecticut CT-1040EZ/Telefile Tax Return and taxman taxman
This document provides instructions for filing estimated income tax payments for the 2009 tax year in Connecticut. Key details include:
- Taxpayers must make estimated payments if their Connecticut income tax minus withholding is $1,000 or more and withholding is less than their required annual payment.
- The required annual payment is 90% of the tax on the 2009 return or 100% of the tax on the 2008 return.
- Estimated payment coupons are due on April 15, June 15, September 15, 2009, and January 15, 2010.
- Taxpayers may owe interest if estimated payments are insufficient by the due dates, even if the total tax is paid by the filing deadline.
US tax court 15 West 17th - re charitable receipt cws and easement valuesPatrick Rowland
This document summarizes a tax court case regarding a charitable contribution deduction claimed by 15 West 17th Street LLC for donating a conservation easement to the Trust for Architectural Easements. The IRS disallowed the deduction in full because the LLC failed to provide a contemporaneous written acknowledgment from the donee organization as required by law. The LLC argued the donee organization filing an amended tax return providing the required information eliminated the need for the acknowledgment. The tax court ruled that the statutory provision allowing this alternative requires regulations that have not been issued, so the general rule requiring the acknowledgment applies.
This document is a payment agreement request form for the Utah State Tax Commission. It allows taxpayers to request a monthly payment plan if they cannot pay the full amount owed on their individual income tax return. Taxpayers provide personal information and details of the requested payment plan such as the monthly payment amount and due date. The form instructions explain how to complete the form and the requirements of the payment agreement if approved.
1. The document provides instructions for Arizona Form 140PTC, which is used to claim a property tax credit or refund.
2. It outlines eligibility requirements, such as being an Arizona resident for all of 2002 and having a household income below certain thresholds.
3. It instructs filers to attach supporting documents like property tax statements or Form 201, depending on whether they owned a home, rented, or lived in a nursing home.
The document is a tax prepayment coupon from the Utah State Tax Commission that provides instructions for making prepayments on individual income tax liability. It explains that prepayments may be necessary if an individual's tax withholding is less than 90% of their current tax liability or 100% of the prior year's liability. It provides a worksheet to calculate the required prepayment amount and notes that interest and penalties may apply if sufficient payments are not made by the filing deadline. The coupon should be sent with payment to the Utah State Tax Commission by the filing due date.
This document discusses investing in US real estate by foreign individuals and provides an overview of key tax considerations. It notes that income tax rates vary by state from 10-39.6% for individuals and 15-38% for corporations. Capital gains tax is generally 15% but may increase to 20% for higher income brackets. Sale of real property by a foreign person may require FIRPTA compliance. Estate tax exclusion is $5.34M for US persons but only $60K for foreign persons. The simplest ownership structure is direct ownership by a foreign individual but this is subject to FIRPTA withholding and estate tax. The recommended structure uses a foreign corporation and US corporation to avoid these issues but is more expensive. FIRP
What Happens Off-Shore, Stays Off-Shore - NOT oliviajrowe
Dennis Brager discusses the issues and penalties surrounding undisclosed foreign bank accounts and assets. FBARs must be filed for foreign accounts over $10,000 and failure to do so can result in both criminal and civil penalties, including prison time and fines up to 50% of the highest account balance. The IRS now has access to data from FATCA, Swiss bank tax amnesties, whistleblowers, and foreign banks closing accounts of noncompliant U.S. clients. The offshore voluntary disclosure program allows taxpayers to avoid criminal prosecution but charges a penalty of 27.5% of undisclosed assets. Strict documentation is required for the disclosure.
Numerous US individuals own overseas assets or have an interest in them. The IRS may penalize these taxpayers if they fail to report these assets on their tax filings. Consequently, the streamlined filing compliance procedure exists to assist these individuals with:
– A streamlined process to file delinquent or amended tax returns;
– Resolving tax and penalty procedures for filing delinquent or amended returns; and
– Resolving penalty and tax obligations
This webinar will guide you through the complexities of Streamlined Filing Compliance Procedures and make your US Tax Journey Exponentially easier!
Takeaways:
Topics that we will cover in the upcoming webinar:
1. Introduction to Streamlined filing
2. Eligibility Criteria for Streamlined Filing
3. Types of Streamlined Filing
– Streamlined Foreign Offshore Procedures
– Streamlined Domestic Procedures
4. Other rules and regulations
5. FAQs, and much more
Who Attended?
- US Citizens Living in the US and Outside
- CPAs, EAs, CAs, ACCAs
- Tax and Accounting Professionals with US Citizens as their clients
Why And Where To Set Up A Foreign Trust For Asset ProtectionEllington78Ellington
A foreign trust must satisfy certain reporting requirements to the IRS, including filing Form 3520-A annually. The key forms are Form 3520-A, Form 5471 if owning a foreign corporation over 10%, and Form 8938 for foreign financial assets over a threshold. Whether a trust is domestic or foreign determines special reporting, and penalties can be imposed for failing to meet reporting rules. Understanding how and when to report a foreign trust to the IRS is important to avoid issues.
The document discusses cross-border tax planning and compliance for US persons living in Canada. It outlines how to determine US tax exposure based on citizenship, residency and foreign assets. US persons are required to file annual tax returns, FBARs, and disclosures of foreign accounts, investments and businesses. Failure to comply can result in penalties and criminal charges. Integrated planning is needed to structure assets and income to minimize US tax obligations while meeting Canadian regulations.
International Taxation – US Citizen and Green Card Holder (Resident Alien)Smart Accountants
With the Tax Season shaking the entire industry, only something valuable should divert your attention. And believe us when we say that our webinar series, which covers a variety of highly engaging topics around U.S Taxation is exactly what you should be focusing on!
FBAR and US Taxes for Expatriates - Intercam Presentation , Ixtapa, MexicoDon Nelson Tax Attorney
- US citizens living abroad, including in Mexico, are required to file US tax returns and report foreign financial accounts over $10,000. Failure to do so can result in penalties.
- There are tax treaties between the US and Mexico to exchange tax information. The IRS is increasing audits of US expatriates due to inaccurate filings. It's important for expats to properly report all foreign income and assets.
- Expats have options if they have not filed previously, including streamlined filing programs. Filing past returns or disclosures without penalties is possible in some cases. Proper filing and documentation is important to avoid audits.
This document summarizes tax planning considerations for Chinese nationals relocating to the United States for EB-5 investment or executive positions. It discusses how to determine US tax residency status, income tax rates and treaty planning. Pre-arrival planning tips are provided like realizing income before arriving, undertaking transactions to step up the basis of assets, and establishing foreign trusts or gifting assets. Reporting requirements for non-US investment entities are also summarized.
This document provides information on cross-border tax and estate planning solutions for Chinese clients investing or doing business in the United States. It discusses typical structures like using foreign corporations and trusts to hold US and foreign assets. It also covers topics such as US tax residence rules, foreign reporting requirements, expatriation tax, and the EB-5 immigrant investor program.
This document provides an overview and summary of Canada-U.S. cross-border tax issues presented by Alpesh Joshi, CA, CPA. It discusses the services provided by AJPCA related to cross-border tax compliance, international tax, and consulting. It highlights some key impacts of the new fifth protocol to the Canada-U.S. Tax Treaty, including changes to the definition of permanent establishment and treatment of hybrid entities. It also covers issues like foreign bank reporting requirements, obtaining an ITIN number, and nexus for U.S. income and sales tax purposes. The presentation aims to make bankers aware of common cross-border tax concerns faced by individuals and corporations.
The document discusses recent updates from the U.S. Treasury regarding regulations on the Foreign Account Tax Compliance Act (FATCA). It outlines FATCA's goal of ensuring tax compliance for U.S. taxpayers' offshore financial assets and accounts. Key points include: expanded categories of compliant foreign institutions, extended timelines for requirements, and reduced burdens for foreign institutions. FATCA now joins existing disclosure regimes for foreign bank accounts, offshore entities, and specified foreign assets. Implementation of FATCA provisions will take place between 2013-2017.
This document provides an overview of Canada-U.S. cross-border tax issues presented by Alpesh Joshi, CA, CPA. It discusses current tax issues, services provided related to cross-border tax compliance, and how recent changes to the Canada-U.S. tax treaty may impact Canadian companies doing business in the U.S. It also briefly summarizes issues like personal tax obligations for snowbirds, property ownership structures to minimize estate taxes, and transfer pricing regulations.
The Legal and Tax Considerations for Chinese HNWIs Investing in Australia Pro...clebourgeois
Chinese HNWIs are investing heavily in Australian property, with an estimated $70 billion in demand over the next 5 years. This document outlines the key legal and tax considerations for such Chinese investors. Legally, foreign investors must obtain approval to purchase properties that increase housing supply, such as new developments, vacant land for construction, or properties for redevelopment. Failure to obtain approval can result in fines or imprisonment. Tax considerations include paying both Australian and Chinese capital gains tax on profits, as well as income tax, land tax, and being able to deduct certain property expenses.
This document summarizes visa options for foreign investors in the United States, including the E-2 visa for treaty investors and immigrant visas for investors investing $1 million or more. It outlines the requirements for these visas such as investment amount, business ownership percentage, and job creation. It also provides details on evidencing the legitimate source of investment funds, capitalization of the business, and managerial control as required by the applications.
Foreign bank account reporting requirements were established in 1970 to address concerns about US persons hiding assets and evading taxes through foreign accounts. In recent years, the IRS has stepped up enforcement of these FBAR reporting requirements, including increasing penalties, expanding the definition of foreign accounts, and collaborating with foreign governments like Switzerland to obtain client names. Tax preparers must also exercise due diligence in inquiring about foreign accounts to avoid penalties for themselves.
This document provides information about tax considerations for Canadian snowbirds traveling to the United States. It discusses how snowbirds can be considered non-resident aliens or resident aliens by the IRS depending on their length of stay and ties to the US. It notes that both Canada and the US tax worldwide income based on residency, so snowbirds need to be careful not to be deemed residents of both countries. The document also outlines the substantial presence test and closer connection exemption that determine residency status, and lists various social, economic, and personal ties that are considered for the closer connection test. Finally, it discusses the US estate tax implications for non-residents based on their US situs property holdings.
Tax Planning and the New Tax Law 11/18/2010joeliss410
This document provides an outline and overview of tax planning opportunities under the new tax law passed in 2010. Key provisions include increased bonus depreciation and Section 179 expensing limits, tax exclusions for certain small business stock gains and health insurance costs, and liberalized rules around retirement plan rollovers and cell phone expenses. Stricter information reporting is also required for rental property income. The document also briefly outlines some additional year-end business tax planning strategies for Illinois, including various job creation tax credits.
Rowbotham & Company is a full-service CPA firm with offices in San Francisco and Silicon Valley. The firm provides audit, accounting, and domestic and international tax services to individuals and businesses. The document outlines key tax changes under the new tax act and answers international tax questions, including reporting requirements for foreign accounts and trusts. It also discusses strategies for expatriation and estate/gift tax planning.
Similar to 15 07-24 Puerto Rico Income Tax Incentives (20)
14 12-18 Everything You Always Wanted To Know About Public Charities But Were...Bruce Givner
Tax deductible vs. tax exempt; charities vs. other tax-exempt entities such as trade associations; UBTI - unrelated business taxable income; Forms 990 and 990-T; self-dealing rules; Section 4940 and the 2% excise tax on investment income, 4941 and the taxes on self-dealing, 4942, 4943, 4944 and 4945; intermediate penalties and Section 4958; private foundations vs. public charities; private operating foundations; medical research organizations; types of public charities;
What information would your trustee or executor need and/or want to know if you died suddenly? Where is the information about your assets, debts, estate planning documents, relatives, retirement benefits, insurance policies? This checklist is designed to get you to put all of that information in one place, and to update it regularly.
14 09-04 Everything You Always Wanted To Know About Post-Mortem PlanningBruce Givner
Portability vs. disclaimer to a bypass trust; getting rid of an unwanted bypass trust; notice of proposed action vs. a 17200 petition; valuable information for the successor trustee; Heggstad assignment of assets; modified financial statement for the successor trustee; funding the subtrusts; first spouse post-mortem checklist; Prop. 13 problems; 16061.7 notice;
California and federal forms; does it make sense to use non-California entities?; asset protection benefits; 3 different types of asset protection; problems with LLCs; gross receipts tax; best states for LLCs; the best structure; the rollout LLC; FLPs using LLCs; limited partnerships instead of LLCs; LLCs for tax-exempt entities;
14 05-17 the most common flaws in estate planningBruce Givner
The most common flaws in estate planning including the failure to get started, the failure to maintain fresh documents, the failures in many documents, failures in asset transfers, failure to consider family issues, and failures through overplanning and underplanning.
How Parents Keep Control Both During Their Lifetimes And After They Are DeadBruce Givner
Irrevocable trusts are required if you want to engage in estate tax planning, asset protection planning (creditor planning) and even in a great deal of income tax (including capital gains tax) planning. However, parents are not thrilled at the idea of having to give away assets to a trust that they cannot revoke!! Do you mean that they can't change it? What if they change their minds about their children? About the trustee? Happily, there are many ways to make the parents comfortable that even though the trust itself is unable to be revoked, it is flexible. The parents, of course, pick as the initial trustee the person they trust to do whatever he or she is told without question but simply out of loyalty. More importantly, the parents can - at any time, without a reason - remove the trustee and name a new one (as long as the new one is not "related or subordinate" as defined in IRC Section 672(c)). The parents can advise the trustee to drop the assets down into a single member LLC and appoint the parents as the non-managing members. The trust can have a protector who can be given the power to remove the trustee; to change the allocation among the children; to add grandchildren and spouses of heirs and charities as beneficiaries; to change the manner of distribution to the heirs. Under California law if all of the beneficiaries and the grantors agree, they can amend an irrevocable trust without having to go to court. There are also other ways to change an irrevocable trust, e.g., decanting to a new trust with better provisions. The trust can start off as a grantor (disregarded) trust for income tax purposes and it can "flip" or "toggle" to a complex trust and, perhaps, flip back again. So, the goal of this presentation is to make people aware that there are ways to make parents comfortable with irrevocable trusts, without which planning would be difficult, if not impossible.
Everything You Always Wanted To Know About Family Trusts But Were Afraid To AskBruce Givner
Family Trusts. Living Trusts. Inter Vivos Trusts. Revocable Trusts. Synonyms for trusts that are "Will substitutes." They help avoid probate and the need for a conservatorship. They help reduce the fees, including trustee and attorney fees, and delays of probate. Most of the documents are boilerplate, but why? What's wrong with using LegalZoom and other document preparation software? Must you file an IRS Form 1041 for a family trust? Must the living trust get its own EIN? What is a subtrust? What is an administrative trust? What is a grantor? A protector? A complex trust? How is competence determined? Are "no contest" clauses enforceable? Are illegitimate children "heirs"? Must a living trust be notarized? Must it be recorded? What is a "pourover" Will? What is a codicil? What is a holographic will? What is a personal property memorandum? What makes a power of attorney "durable"? What is a health care directive?
What is a "springing" power of attorney? What is a "pot" trust? What is a "specific" bequest? When should I use a corporate trustee? What's the difference between a fiduciary bond and fiduciary insurance? What is a trust certificate? What is a "blanket" assignment of assets? What is "per stirpes"? What is the rule against perpetuities?
Investing Retirement Plan Assets: What Are The Limits?Bruce Givner
The Internal Revenue Code and the Title I of ERISA (administered by the U.S. Department of Labor) have restrictions on how retirement plan assets can be invested. For example, certain investments will cause UBTI (unrelated business taxable income) to what is otherwise a tax-exempt trust. Certain investments may cause prohibited transactions with the resulting excise tax under IRC Section 4975. There are also the general fiduciary rules governing trustees generally, e.g., the duty to diversify. This handout is designed to advise the trustee and the plan sponsor on how to avoid the pitfalls.
Everything you ever wanted to know about trustees: What does it mean to be a trustee? What are your responsibilities and liabilities? What makes a good trustee?
For more information, please visit us at www.givnerkaye.com
An overview of the entire state administrative process. Learn about when you can settle during the process, some great publications to read up on, how the audit wraps up, settlement, and what to do if you don't like the audit result.
For more information, please visit us at www.givnerkaye.com
Golden Rule of Interpretation by Puja Dwivedilegalpuja22
introduction to the Golden Rule of Interpretation
Definition and Origin:
The Golden Rule of Interpretation is a guiding principle utilized in legal systems worldwide to decipher and implement laws justly and reasonably.
Its roots trace back to ancient legal philosophies, notably derived from the Latin maxim "interpretatio cessat in claris," meaning interpretation ceases when the meaning is clear.
Purpose and Function:
The primary objective of the Golden Rule is to empower judges and legal interpreters to depart from the literal interpretation of statutes when adherence to such interpretations would lead to absurd, unjust, or unreasonable outcomes.
Unlike the strict adherence to the literal meaning prescribed by the Literal Rule, the Golden Rule allows for flexibility in interpretation, ensuring the law's application aligns with the broader principles of justice and fairness.
Evolution and Adaptation:
Over time, the Golden Rule has evolved to meet the changing needs and societal values of legal systems. It adapts to modern contexts, technological advancements, and evolving understandings of justice.
Its application varies across different legal jurisdictions but remains a fundamental tool in statutory interpretation worldwide.
Literal Rule vs. Golden Rule
Literal Rule:
The Literal Rule is a traditional approach to statutory interpretation that mandates strict adherence to the plain and literal meaning of the words used in a statute.
Under this rule, judges are expected to interpret legislation based solely on the language's explicit wording, without considering underlying intentions, societal implications, or potential absurdities that may arise from a literal interpretation.
Golden Rule:
In contrast, the Golden Rule of Interpretation provides judges with the discretion to depart from the literal meaning of statutes when necessary to avoid absurd or unjust outcomes.
It serves as a balancing mechanism, allowing courts to interpret laws in a manner that aligns with broader principles of justice, fairness, and legislative intent.
While the Literal Rule focuses solely on textual analysis, the Golden Rule recognizes the need for flexibility and adaptability in legal interpretation, particularly in complex or ambiguous situations.
Illustrative Example:
Case Law Example: State of Madhya Pradesh v. Azad Bharat Financial Company (1967)
This case exemplifies the application of the Golden Rule, where the literal interpretation of the Opium Act of 1878 would have led to the unjust confiscation of a vehicle due to the presence of contraband.
By applying the Golden Rule, the court interpreted the statute in a manner that prevented injustice, highlighting the rule's essential role in safeguarding fairness and equity in legal proceedings.
The Law of Dogs in Sectional Title SchemesAshwini Singh
The Law of Dogs in Sectional Title Schemes (in South Africa):
-PCR 1(1) of the STSM Regulations:
“The owner or occupier of a section must not, without the trustees’ written consent, which must not be unreasonably withheld, keep an animal, reptile or bird in a section or on the common property.”
-PCR 1(2) of the STSM Regulations:
“An owner or occupier suffering from a disability and who reasonably requires a guide, hearing or assistance dog must be considered to have the trustees’ consent to keep that animal in a section and to accompany it on the common property.”
-Subsection 39(2)(c) of the CSOS Act:
“An order declaring that an animal is being kept in a community scheme contrary to the scheme governance documentation, and requiring the owner or occupier in charge of the animal to remove it…"
-The Trustees of The Ridge Body Corporate v Wijne:
Adjudication Order Paragraph 47:
“The continued conduct [of the Respondents] to keep pets in their unit without authorisation of the Trustees of the Ridge is contrary to the provisions of the scheme’s conduct rules [and] is a violation of the rules and amounts to usurping the authority of the Trustees if not disregarding it…”
Adjudication Order Paragraph 50:
“In terms of the scheme rules, it is not permissible for an owner or occupier of a unit to keep an animal or pet without prior authorisation of the trustees. In the premises, [the Respondents] are found to have acted in contravention of the scheme rules of The Ridge and have acted contrary to the provisions of Section 39(2)(b) of the Community Schemes Ombud Service Act…”
Adjudication Order Paragraph 53.1:
“The Respondent … is ordered to remove the pet dog and parrot kept in … The Ridge and out of the scheme within 30 days of delivery of this order.”
A petition for justice. The witness provided false delusional testimony. The court made several errors which include denying witness to testify. The abuser has relationship with the court. The victim is disabled and can't defend herself due to communication disability.
Introduction
FIU IND, short for Financial Intelligence Unit - India, is an agency responsible for receiving, analyzing, and disseminating information relating to suspicious financial transactions. It plays a crucial role in combating money laundering and terrorist financing. FIU registration is mandatory for certain financial entities to ensure they comply with the legal requirements and contribute to the integrity of the financial system.
The Lockdown on Minimum Wage: Everything you need to know:tanisha333186
The Minimum Wages Act, of 1948, serves as the overarching legislation governing minimum wage determination and enforcement across the country. This act outlines the procedures for fixing and revising minimum wage rates, taking into account factors such as cost of living, inflation, and skill levels. Additionally, it mandates the establishment of Minimum Wage Advisory Boards at the state and central levels to advise the government on wage-related matters.
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Efforts to Accelerate the Development of Gaming Industry in Indonesia Through...AHRP Law Firm
Presidential Regulation No. 19 of 2024 on the Acceleration of the Development of the National Game Industry was promulgated on 12 February 2024. This presidential regulation accelerated and optimized the potential of games in Indonesia as one of the growth sectors of the creative-based economy. Find out more our insights about this topic in our Legal Brief publication.
An example of a petition written pro-se by the victim to defend against delusional false accusation by an abuser.
Writ of Certiorari written by an autistic defendant who is a victim of harassment and was falsely accused by her very own abuser.
Individuals with autism has difficulties in communicating, and this gives plenty of advantages for abusers because autistic individuals are naive and not able to defend themselves due to communication issues. The abuser in this case happens to be a school principal who bullies and harasses disabled students and parents on regular basis, but she is able to walk away free because of her craftiness and her exceptional abilities to lie. She is a pathological liar and she is able to deceive law enforcement and the court. This document describes the truth and the ordeal that one of her victims had to go through without being able to get help because the abuser was able to manipulate a large number of people. This document also shows how the current justice system fails to accommodate disabilities especially autism spectrum disorders. Despite a campaign by Pennsylvania Supreme Court to enable autistic individuals to access justice, the courts in Pennsylvania, including the Supreme Court itself is still far far away from understanding Autism. Autistic people have to suffer in silence, and many of them are victims of abuse but they are not able to defend themselves. This explains why suicide rates amongst autistic populations are extremely high.
parliamentary and presidential form government.ppt
15 07-24 Puerto Rico Income Tax Incentives
1. LAW OFFICES
GIVNER & KAYE
A PROFESSIONAL CORPORATION
SUITE 445
12100 WILSHIRE BOULEVARD
LOS ANGELES, CALIFORNIA 90025
www.GivnerKaye.com
BRUCE GIVNER
(bruce@GivnerKaye.com)
OWEN D. KAYE
(owen@GivnerKaye.com)
KATHLEEN GIVNER
(kathy@GivnerKaye.com)
NEDA BARKHORDAR
(neda@GivnerKaye.com)
PHONE (310) 207-8008
(818) 785-7579
FAX (310) 207-8708
(818) 785-3027
July 24, 2015
Puerto Rico1
Income Tax Incentives2
Residence
Requirement: Person.
(i) Physical Presence Test. Usually 183 days3
residence in Puerto
Rico per year.4
(ii) Tax Home Test. Do not have a tax home outside P.R.
(iii) Closer Connection Test. Do not have a closer connection to the
U.S. or a foreign country than to P.R.5
Corporate. 80% of the work, measured by payroll, performed in P.R.
Recommendation: do not keep a residence in the U.S.
Follow all of the objective criteria in FTB Publication 1031.6
Internal Revenue
Code: §9337
exempts P.R. residents from paying U.S. income tax on their
1
La isla del encanto – The Island of Enchantment. Officially the Commonwealth of Puerto Rico. An
unincorporated territory of the U.S. Total permanent population of 3.7 million, of whom 2.5 million live in the San
Juan metropolitan area, with 4 million visitors per year.
2
Based on U.S. Virgin Islands Economic Development Commission programs.
3
If you arrive at one minute before midnight, that counts as a full day in Puerto Rico. One hour time difference
from the East Coast. Reg. §1.937-1(c)(3)(i)(A).
4
Reg. §1.937-1(c)(1): “In general. A U.S. citizen or resident alien individual…satisfies the [the presence trust] if
that individual— (i) Was present in the…possession for at least 183 days during the taxable year; (ii) Was
present in the relevant possession for at least 549 days during the 3-year period consisting of the taxable year
and the 2 immediately preceding taxable years, provided that the individual was also present in the relevant
possession for at least 60 days during each taxable year of the period; (iii) Was present in the U.S. for no more
than 90 days during the taxable year; (iv) During the taxable year had earned income…in the U.S., if any, not
exceeding in the aggregate the amount specified in §861(a)(3)(B) [$3,000] and was present for more days in the
relevant possession than in the U.S.; or (v) Had no significant connection to the U.S. during the taxable year….”
5
When traveling to the U.S. you must fill out an entry form. Indicate that you live in P.R. and use your P.R.
address on any official government form.
6
“Factors to consider are as follows: amount of time you spend in California vs. amount you spend outside of
California; location of your spouse/RDP and children; location of your principal residence; state that issued your
driver’s license; state where your vehicles are registered; state in which you maintain your professional licenses;
state in which you are registered to vote; location of the banks where you maintain accounts; the origination
point of your financial transactions; location of your medical professionals and other healthcare providers
(doctors, dentists, etc.), accountants and attorneys; location of your social ties, such as your place of worship,
professional associations, or social and country clubs of which you are a member; location of your real property
and investments; permanency of your work assignments in California. This is only a partial list of the factors to
consider. Consider all the facts of your particular situation to determine your residence status.”
2. LAW OFFICES
GIVNER & KAYE
A PROFESSIONAL CORPORATION
Puerto Rico Income Tax Incentives
July 24, 2015
Page 2 of 3
P.R.-sourced income. Must file IRS Form 8898.8
P.R.’s Department of
Finance has exclusive right to tax local income.9
Puerto Rico’s
New Laws: General. 2012 – tax treatment is guaranteed for 20 years.10
Businesses. Act 20, the Export Services Act.11
Perform services in P.R.
on behalf of customers outside P.R. Cannot have branches or staff in
the U.S. Pay a flat 4% rate with profits paid to owners tax free. Must
take a reasonable salary which is taxed at up to 33%. Must have 3
employees, but you and your spouse can count as two. Six months to
comply. Labor laws are rigorous.
No. Live in the U.S. and set up a P.R. company that receives a market-
based fee for tasks it performs. Once enough cash has built up take up
residence in P.R. After a few years move back to the U.S. without
paying tax on the profits. If a U.S. person owns more than 10% of the
P.R. company it is a controlled foreign corporation and gives rise to
passive foreign investment company issues (perhaps 52% tax in U.S.).
7
“The following items shall not be included in gross income and shall be exempt from taxation under this
subtitle: (1) Resident of Puerto Rico for entire taxable year In the case of an individual who is a bona fide
resident of Puerto Rico during the entire taxable year, income derived from sources within Puerto Rico (except
amounts received for services performed as an employee of the United States or any agency thereof); but such
individual shall not be allowed as a deduction from his gross income any deductions (other than the deduction
under section 151, relating to personal exemptions), or any credit, properly allocable to or chargeable against
amounts excluded from gross income under this paragraph. (2) Taxable year of change of residence from
Puerto Rico In the case of an individual citizen of the United States who has been a bona fide resident of
Puerto Rico for a period of at least 2 years before the date on which he changes his residence from Puerto Rico,
income derived from sources therein (except amounts received for services performed as an employee of the
United States or any agency thereof) which is attributable to that part of such period of Puerto Rican residence
before such date; but such individual shall not be allowed as a deduction from his gross income any deductions
(other than the deduction for personal exemptions under section 151), or any credit, properly allocable to or
chargeable against amounts excluded from gross income under this paragraph. ”
8
“Statement for Individuals Who Begin or End Bona Fide Residence In a U.S. Possession.” Required by
§937(c) if you have worldwide gross income of more than $75,000.
9
§734 of Title 48 of the U.S. Code. The Internal Revenue Code For A New Puerto Rico. Rates are 0% up to
$12,000; 7% up to $26,000; 14% up to $42,570; 25% up to $62,750; and 33% over $62,750.
10
Under the 1950 Puerto Rico Federal Relations Act, the federal government treats Puerto Rico as a state for
most purposes. Therefore, the contract with a taxpayer is enforceable against both the governments of Puerto
Rico and the U.S.
11
Specifically mentioned in the Act: E-commerce businesses, particularly those which provide or publish digital
products and services; consulting firms of any kind, particularly those which do not require substantial travel to
the customer to provide the service; investment management; graphic design; internet marketing and
copywriting services; investment relations and PR; inbound and outbound call centers, especially bilingual call
centers; remote tax and legal consultancy, including tax preparation work; software development; R&D;
hospitals and laboratories; educational and training centers; and storage and distribution centers.
3. LAW OFFICES
GIVNER & KAYE
A PROFESSIONAL CORPORATION
Puerto Rico Income Tax Incentives
July 24, 2015
Page 3 of 3
Also, capital appreciation is taxed at 39% in P.R.
Individuals. Act 22 benefits business owners and active traders. $5,000
application fee.
Planning. Great to move if you expect massive capital gain in the next
18 to 36 months. Move back to the U.S. afterwards.
No tax on: (i) locally sourced interest;
(ii) locally sourced dividends;
(iii) all short-term and long-term capital gains accrued after becoming
a bona-fide resident of Puerto Rico.
U.S. tax on: (i) public company dividends;
(ii) mainland private business profits;
(iii) mainland interest;
(iv) deferred compensation earned in the states;
(v) Social Security benefits; and
(vi) U.S. real property (directly or through entities).
Phase-out: unrealized capital gain:12
(a) if sold within 10 years after move:
(1) full U.S. tax;
(2) 10% Puerto Rico tax (creditable against U.S. tax).
(b) if sold more than 10 years after move:
(1) no U.S. tax;
(2) 5% Puerto Rico tax.
Persons Who May
Qualify: Returning Puerto Rico residents who left before 2006.
Must become a resident of Puerto Rico by December 31, 2035.
12
Reg. §1.937-2(f)(1)(vi)(B). “In the case of property other than marketable securities, the portion of gain
attributable to the possession holding period…will be determined by multiplying the total gain on disposition of
the property by a fraction, the numerator of which is the number of days in the possession holding period and
the denominator of which is the total number of days in the individual's holding period…. …[If] the individual is a
bona fide resident of the relevant possession for more than a single continuous period, the number of days in
the numerator will be the aggregate of the number of days in each possession holding period. [T]he
denominator will include days that are required to be included in an individual's holding period §735(b), §1223,
and any other applicable holding period rule in the Internal Revenue Code.”
Example: assume that Joe’s 50% of the stock of a closely held California corporation is worth
$2,000,000 on the day he becomes a resident of P.R. and assume he has owned it for 10 years. Two years
later the other 50% shareholder buys Joe’s stock for $6,000,000. Joe’s holding period is 12 years, of which 2
years was in P.R. So 2/12ths or 16.67% of the $4,000,000 gain is allocable to P.R.