US Taxpayers given some Reporting Relief on certain Foreign Trust Investments

Jurate Gulbinas   |   10 Mar 2020   |   2 min read

Section 6048 requires US taxpayers to make an annual report regarding financial or asset transfers in relation to the receipt of distributions from foreign trusts. Taxpayers can be penalised if they fail to comply. Unfortunately many taxpayers have been caught out when it comes to reporting foreign retirement investments and other trusts. 

On March 2nd 2020 the IRS released Rev. Proc. 202-17. This change comes into effect on March 16 and provides taxpayers with certain foreign investments with an exemption from section 6048 reporting requirements on those investments. Accordingly, eligible US citizens with some tax favored foreign retirement investments and other trusts, have less duties in their reporting requirements. Furthermore, eligible individuals can now apply for a refund of any penalties that they have incurred as a result of section 6048 reporting requirements with their applicable tax-favored foreign trusts. 

The reason behind the change is that there are already a number of restrictions imposed by the countries where those trusts are located and there are already additional reporting requirements in the US under section 6038D regarding interests in these trusts. This alleviates the pressure of being penalized for meeting the section 6048 reporting requirements and reverses the penalties previously imposed in such cases. 

Once the change comes into place it will apply to any prior tax year that is still open. 

One of the reasons this relief is important is because it covers a requirement that many taxpayers and tax professionals haven’t realized was in place. This is because people tended to assume that the tax and reporting requirements were deferred until the point of retirement and they didn’t understand which international information reporting forms were to be used. Alleviating this reporting requirement will help reduce a lot of confusion in the field. 

If you have a foreign retirement or trust investment that may qualify you should look into Rev. Proc. 2020-17 or seek further advice for your specific situation. 

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This article relates to foreign business founders with an active business, who are moving to the US. There is a risk that foreign earnings may be double taxed when your organisation is taxed as a US entity. This is due to the application of US attribution rules (Controlled Foreign Corporation (CFC) rules) and Passive Foreign Investment Company (PFIC) rules.

To avoid being double taxed and ensure that foreign tax credits can be appropriately applied, it may be advisable to make a check-the-box election. This election essentially means that foreign corporations are choosing to elect their US tax status at the point in time that the US tax system becomes ‘relevant’ to them.

This check-the-box system is a tax regime that doesn’t just impact organisations that are set up in the US. It can also impact Australian businesses and global businesses when the foreign founder of the corporation moves to the US.

When does the US tax system become ‘relevant’ to a foreign corporation:

The US tax system is considered to be ‘relevant’ to a foreign corporation when one of the following applies:

a) the foreign corporation derives US sourced income;

b) the foreign corporation is required to file an income tax return in the US; or

c) the owner of a foreign corporation becomes a US tax resident (ie a US Person).

Why might a check-the-box election be made?

The most basic reason for making the check-the-box election is to ensure that the owner of the corporation in the US is properly credited with the foreign tax payments. A check-the-box election will avoid the attribution of income under CFC rules or the loss of long term capital gains tax rate discounts when shares are transferred in a passive foreign investment company (PFIC).

When will a foreign corporation be a CFC?

When US shareholders own more than 50% of the shares, either directly or indirectly, then the foreign corporation will be considered to be a controlled foreign corporation (CFC). To be considered a ‘US shareholder’ the person must own more than 10% of the voting rights or stock value of the foreign company.

When is a foreign corporation a PFIC?

A passive foreign investment company (PFIC) exists when one of the following two conditions are satisfied:

  1. Passive investments generate at least 75% of a corporation’s gross income (as opposed to regular business activities); or
  2. At least 50% of the corporation’s assets create passive income. Passive income includes interest, dividends and capital gains.

What is a foreign eligible entity?

A foreign eligible entity is defined by whether a member has limited liability or not. This is a default classification under the check-the-box regulations. When all members of the corporation have limited liability the US taxes the foreign eligible entity as a corporation. When at least one member does not have limited liability the entity is not a foreign eligible entity.

An eligible entity may make a check-the-box election to opt out of the default classifications.

Warning on making an election after default classification has been made

It is important to make your election prior to the default classification being applied. This is because making a later election will change the organisation’s classification. Such a change in classification can trigger a liquidation event.

When you should make a check-the-box election:

To ensure the check-the-box election is made appropriately you should consider making the election when you meet all of the following conditions:

  1. you own a foreign corporation
  2. the US tax system is relevant for your corporation
  3. you need to apply foreign tax credits against your US corporate tax regime
  4. you wish to avoid applying the CFC or PFIC rules.

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Jurate Gulbinas   |   17 Feb 2017   |   5 min read

US tax residents (citizens, permanent residents, and substantial presence test aliens) are required to pay income tax on their worldwide income and non residents are only required to pay tax on their US sourced income.

First, do you have to file tax returns?

Both US tax residents with worldwide income and non residents with US sourced income need to file US tax returns. A non-resident will have US sourced income if they they are engaged or considered to be involved in a trade or business in the US within any given year.

Determining your tax residency

Non-citizens are called residents if they are permanent residents (i.e. they hold a green card) or if they pass the substantial presence test. They are referred to in the Internal Revenue Code as resident aliens. A non-citizen will pass the substantial presence test if they spend at least 31 days during the current year within the US and if, when you apply the 3 year aggregation formula set out within the Internal Revenue Code to their circumstances, they are deemed to have spent more than 183 days in the US (current year x 1 + year prior to current year x 1/3 (Year 2) + year prior to Year 2 x 1/6). If you do not hold a green card or do not pass the substantial presence test you are considered a non-resident alien.

Tax treatment of citizens and resident aliens

Resident aliens use the same filing statuses as citizens and are able to claim the same deductions and tax credits as citizens. Resident aliens must report all forms of income received including wages, investment returns, and income received from foreign governments including pensions. There are exceptions to the residence test that provides many of the legal aliens with exemptions from reporting global income.

Exemptions for resident aliens

  • Those who commute from Canada or Mexico regularly do not count commuting days as residence days for the substantial residence test.
  • Those who are able to prove that they had a tax home in another country during the years they are not present in the US for 183 days. This tax home is then considered the principle place of business or the primary residence of the individual.
  • Exempt persons include those who are in the US temporarily including teachers, students, trainees, professional athletes, and employees of non-US governments.
  • Tax treaty exemptions apply to those who are from certain countries which may have favorable tax treaties with the US.

Tax treatment of non-resident aliens

Non-resident aliens who have US earnings are only required to pay income tax on the income that is generated from a US-based source. Any foreign income does not have to be reported on a US tax return and is not considered tax-eligible by the IRS. For example, if an Australian business person owns and operates a business in Australia and owns a business located in the US, only the income generated by the US-based business is considered taxable. Also, if that person realizes investment income in the US that is not from a US source, the income from that investment is taxable at a flat rate of 30%, unless otherwise specified by a tax treaty. It is important for non-residents to keep strict records of their global income as they should report it to the IRS as evidence of their compliance with the regulations.

Will I have to pay tax twice on my income from another country?

Good news, if you are paying tax on foreign-based income you may be eligible for foreign tax credits that reduce your burden in the US. Individuals can claim a tax credit for taxes levied by another government on foreign income. Any foreign taxation needs to be reported on schedule A of personal tax return form 1040. In most cases this reduces the amount of taxable foreign income for individuals with global income. There are four criteria for foreign tax to be a deduction on your US tax returns. First, the tax must be imposed on you. You must also have paid the tax. The tax must be a real, legal foreign tax liability and it must be an income tax.

The IRS also operates with a foreign earned income exclusion which is available to those who meet certain criteria. While citizens and resident aliens who live abroad must still report their global income, they may be eligible to exclude all or part of their foreign earnings from US federal taxation.

It is very important to comply with US tax requirements and file your personal returns as necessary. While these laws may seem punitive to those who operate in international markets, they are the rules imposed by the US government and there are penalties and fines on those who do not comply. International tax law is complicated. If you have multiple international income streams, it is critical to get advice from an expert who has intimate knowledge of international tax regulations to help you to make the most of any tax credits and deductions available to you in order to minimize your overall tax burden.

CST Tax Advisors has specialized in helping individuals with international interests to navigate these complicated regulations and requirements for 25 years. The accountants and tax professionals here serve clients from offices spanning the globe and provide intelligent advice to help you protect your wealth.

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Form 8938 for U.S. entities

Jurate Gulbinas   |   23 Jan 2017   |   4 min read

Author: Jurate Gulbinas

As we all start preparing for the new tax season and gathering tax documents, it’s good to review tax laws passed during 2016. In this blog post I am going to discuss Final Regulations regarding reporting Foreign Financial Assets by Specified Domestic Entities.

On February 23, 2016, the IRS issued final regulations regarding the application of reporting obligations under Internal Revenue Code Section 6038D as applied to any U.S. entity which is formed or availed for purposes of holding, directly or indirectly, specified foreign financial assets.

U.S. individual taxpayers have been subject to IRC Section 6038D disclosure requirements for several years. In general, IRC section 6038D requires U.S. taxpayers to report specified foreign financial assets, which include foreign bank and securities accounts, foreign stocks, interests in certain foreign trusts; indeed, an interest in almost any foreign entity, and an interest in a contract or instrument that is issued by a foreign person or that has a foreign person as a party on Form 8938. Please note that Form 8938 is not a substitute for another foreign account reporting Form FinCen 114 or FBAR.

IRC Code 6038D applies to individuals only, however a provision authorizes issuance of the regulations under which entities would be subject to a reporting requirement. It took a couple years for the IRS to finalize its regulations regarding entity reporting.

Reporting requirement applies to a “specified domestic entity”. IRS Code Regulations 1.6038D-6 explain that a specified domestic entity is a “domestic corporation, partnership, or a trust”, if such entity is “formed or availed of for purposes of holding, directly or indirectly, specified foreign financial assets”. In order to be “formed or availed of for purposes of holding specified foreign financial assets”, a U.S. entity has to be closely held by a U.S. person and “at least 50% of the corporation’s or partnership’s gross income for the taxable year is passive income or at least 50% of the assets held by the corporation or partnership for the taxable year are assets that produce or are held for the production of passive income”. This determination is made annually, thus a U.S. entity can have Form 8938 filing required one year and not the next, even if the specified foreign financial assets are the same for both years.

Passive income is defined by regulations as “dividends, including substitute dividends; interest; rents and royalties, other than rents and royalties derived in the active conduct of a trade or business conducted, at least in part, by employees of the corporation or partnership; annuities; capital gains; IRC 988 foreign currency gains; and net income from notional principal contracts”.

It’s worth noting that a taxpayer who holds multiple corporations or partnerships that have an interest in a specified foreign financial asset and are closely held by the same taxpayer, has to treat those entities as if they were a single entity for purposes of the reporting threshold. In that case, each entity is treated as owning the foreign financial assets of each related entity.

Certain U.S. entities are excluded from being specified domestic entities. U.S. grantor trust is excluded from this filing requirement. U.S. grantor trust is not a separate taxable entity for U.S. tax return purposes and U.S. grantor would be required to file Form 8938 to report specified foreign financial assets. In addition, certain domestic trusts are excluded from being specified domestic entities. IRC Regulations 1.6038D-6(d) lists exclusions for the domestic trust, among which is when the trustee has supervisory authority over or fiduciary obligations with respect to the specified foreign financial assets of the trust.
IRC Section 6038D requirement applies to specified domestic entity if the aggregate value of U.S. entity’s specified foreign financial assets exceeds: (1) USD 50,000 on the last day of the taxable year, or (2) USD 75,000 at any time during the taxable year.

2016 Form 8938 was updated already and asks for additional questions to identify type of the filer.

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Disclaimer:
This document is intended as an information source only. The comments and references to legislation and other sources in this publication do not constitute legal advice and should not be relied upon as such. You should seek advice from a professional adviser regarding the application of any of the comments in this document to your fact scenario. Information in this publication does not take into account any person’s personal objectives, needs or financial situations. Accordingly, you should consider the appropriateness of any information, having regard to your own objectives, financial situation and needs and seek professional advice before acting on it. CST Tax Advisors exclude all liability (including liability for negligence) in relation to your reliance in this publication.

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Do you have income tax return filing requirement?

Jurate Gulbinas   |   2 Sep 2016   |   6 min read

Author: Jurate Gulbinas

“I had no tax liability, so I did not need to file….” This is a common phrase from callers to our office.  Is it true?  Well, usually not.

U.S. individual income tax return filing requirements are different for U.S. citizens and residents, and for non-residents.  Let’s start with U.S. citizens and residents (U.S. taxpayers) income tax return filing requirements.

Filing requirement for U.S. taxpayers depends on gross income, filing status, and age.  IRS annual Publication 17 can be your starting point for annual filing requirements.  Let’s say you were single and under the age of 65 at the end of 2015 – you will need to file individual income tax return if your gross income was at least $10,300.  Gross income includes wages, interest, dividends, capital gains, rental income.

Most U.S. taxpayers who live abroad are familiar with a foreign earned income exclusion.  For 2015 up to $100,800 of foreign salary can be excluded from the U.S. taxable income.  Thus a U.S. citizen living outside of U.S. and earning less than $100,800 will not have U.S. income tax liability.  This often confuses U.S. taxpayers and even some tax practitioners abroad.  Zero tax liability does not eliminate U.S. income tax return filing requirements.  In fact, an individual income tax return has to be filed to properly claim a foreign earned income exclusion.

Failure to file U.S. individual income tax return can lead to significant tax and compliance issues.  First, income tax return has to be filed to claim foreign tax exclusion.  Second, income tax return most likely will have Schedule B, Interest and Ordinary Dividends, marked “yes” for a question regarding an interest in a foreign bank account.  You have to file Schedule B with your return if you had an interest in a foreign bank account.  Filing a FinCen Form 114 (also known as an FBAR) does not eliminate the need to report your interest in a foreign bank account on Schedule B.  In addition, FATCA introduced a new form several years ago.  Form 8938, Statement of Specified Foreign Assets, is yet another form that you might have to file.  The reporting thresholds are much higher than FinCen Form 114 – $10,000 accumulated balance.  The IRS website has a handy comparison table of FBAR and Form 8938 requirements which you can access here.

Form 8938 requires you to report not only interest in foreign bank accounts but also your interest in other foreign financial assets, like your 1% interest in that foreign corporation that you invested years ago and forgot.  There is no duplicate reporting for Form 8938, thus if your interest in foreign entity was already reported on any other international information returns (Form 5471, 8621, 8865, 3520 or 3520-A), you do not need to report it again on Form 8938.

Form 8938 noncompliance carries $10,000 penalty under IRC 6038D.  Form 8938 has to be filed with U.S. income tax return.  When a taxpayer has no income tax filing requirement, Form 8938 does not need to be filed.  As you can see finding whether you have an income tax return filing requirement is quite important.  Please remember that numerous international informational forms have to be filed even if taxpayer has no income tax return filing obligations.

A foreign taxpayer has U.S. income tax return filing obligations if he or she has U.S. source income, for example a U.S. rental property.  Usually rental property is not profitable for at least first few years.  It is important to file U.S. income tax return and claim losses on the property.  While not currently deductible, losses will be carried forward and used when foreign owner sells U.S. real estate property.

But what about a foreign investor who invested in U.S. investment partnership and received a schedule K-1 reporting interest and dividends income?  If U.S. partnership properly filed Form 1042-S, there is no return filing obligation for the foreign investor.

Form 1042-S is used to report amounts paid to foreign persons that are subject to income tax withholding (U.S. source income).  Dividends from U.S. corporations are U.S. source income; portfolio interest on the other hand, is not considered to be a U.S. source income.  Thus if your Schedule K-1 shows $100 interest income and $200 dividend income, the partnership would issue two Forms 1042-S.  First form is going to report $100 and exemption code 05 with zero withholding.  It tells IRS that you received $100 interest income and that this interest income is portfolio income.  Another form, Form 1042-S is going to report $200 dividend income and income code 06.  If you live in a country that has a tax treaty with the U.S. (like Australia) and you properly filed W-8BEN, your withholding rate is not standard 30% but instead a lower treaty rate.  For example, according to the U.S. – Australian Income Tax Treaty , dividends are taxed at 15%.

What about if you invested in various U.S. stocks and received dividends and you did not receive Form 1042-S?  You have to file U.S. income tax return (Form 1040NR), U.S. Nonresident Alien Income Tax Return, report U.S. source dividends and pay tax (either 30% general rate or lower treaty rate, whichever is applicable to you).

As you can see, determining filing obligations is a first step for U.S. and foreign taxpayers.  The IRS offers free and useful guidelines on their website at www.irs.gov.  Make sure to check the IRS website and talk to your tax preparer.  If in doubt, check again.  If you find out that you had tax return filing obligations in the past, do not wait, talk to your tax preparer and, if needed, hire international tax specialist.  Ignorance of a tax law is not a reasonable cause for penalty abatements.

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Disclaimer:
This document is intended as an information source only. The comments and references to legislation and other sources in this publication do not constitute legal advice and should not be relied upon as such. You should seek advice from a professional adviser regarding the application of any of the comments in this document to your fact scenario. Information in this publication does not take into account any person’s personal objectives, needs or financial situations. Accordingly, you should consider the appropriateness of any information, having regard to your own objectives, financial situation and needs and seek professional advice before acting on it. CST Tax Advisors exclude all liability (including liability for negligence) in relation to your reliance in this publication.

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Foreign Earned Income Exclusion – You think you don’t need to file a US income tax return? Think again.

Jurate Gulbinas   |   3 Aug 2016   |   6 min read

Author: Jurate Gulbinas

At least a couple times a month I hear, “I live in a foreign country and earn less than foreign earned income exclusion amount.  I do not need to file a U.S. income tax return”.  This is a common misconception among U.S. citizens and Green Card holders living and working outside of the U.S.

Let’s review Foreign Earned Income Exclusion (FEIE or IRC Section 911 exclusion) requirements.  To claim FEIE you must have foreign earned income, your tax home must be in a foreign country, you have to meet either Bona Fide Residence or Physical Residence Test, and you must make a valid election.  Let’s briefly analyze every FEIE requirement below.

What is a foreign earned income?  Usually it’s your salary in a foreign country.  It can also be severance pay, sick leave pay, and noncash income such as an employer provided lodging or car.  If you live outside of the U.S. and you are self-employed, your income from self-employment is earned income.

The IRS has ruled that tax home is the location of the taxpayer’s principal place of employment.  Tax home is not the location of principal residence.  Tax home must be in a foreign country or countries for FEIE purposes.  Antarctica is not considered a foreign country and as a result income earned there won’t qualify as foreign earned income and residence won’t be considered eligible for either bona fide residence or the physical presence test.  There were numerous cases regarding U.S. citizens employed on fishing vessels.  Generally income earned while working on a fishing vessel won’t qualify for the foreign earned income exclusion as fishing vessel do not meet the foreign presence requirement.  For those more interested in fishing vessel employment cases, check Revenue Ruling 73-181 and Bebb v. Commissioner, 36 T.C. 170.

Bona fide residence is another term that is not defined by the Internal Revenue Code.  All relevant facts and circumstances are analyzed for each particular case.  You won’t automatically acquire bona fide resident status by merely living in a foreign country for one year, despite that the bona fide residence test is met if you are a bona fide resident of a foreign country for an uninterrupted period that includes an entire tax year.  As per Section 911(d)(1)(A), your bona fide residence must be maintained for an uninterrupted period that includes an entire taxable year.  Taxable year for U.S. income tax purposes is generally a calendar year.  Thus your first year in a foreign country most likely won’t qualify under the bona fide residency test.

Physical presence test is slightly easier to understand.  You meet this test if you are physically present in a foreign country 330 days during 12 consecutive months.  Once you meet the physical presence test requirements, you are eligible for Section 911 exclusion despite your nature or purposes of your foreign stay. Also keep in mind that 330 days during 12 consecutive months do not necessarily have to start January 1 and end on December 31.  If you left the U.S. June 1, 2015, came back for vacation for 35 days in December 2015 and January 2016, you were physically present 330 days on May 31, 2016 and you are qualified to claim foreign earned income exclusion on your 2015 U.S. income tax return for the period of June 1, 2015 – December 31, 2015.

Most taxpayers do not have any problems meeting the above requirements (foreign earned income, foreign tax home, bona fide residence or physical presence in a foreign country).  The most misunderstood requirement is an election to claim foreign earned income exclusion.  Foreign earned income exclusion is an election that a taxpayer makes on a timely filed U.S. income tax return.  The mere fact that you earned less than the applicable FEIE for the year (USD 100,800 for 2015) and met the other requirements discussed earlier does not automatically qualify you for the Section 911 exclusion.  You have to file Form 2555 and attach it to the timely filed individual income tax return for the year.  In our practice we see many taxpayers who live in foreign countries and who do not file U.S. tax returns for years simply because they misunderstood or were erroneously advised about foreign earned income exclusion requirements.  In many circumstances there were other reporting requirements (such as foreign bank account ownership, interest in a foreign entity or a trust, distribution, gift or inheritance received from the foreign entity or foreign individual).

In a recent tax conference, IRS speakers emphasized Form 2555 and a foreign tax home requirement to claim foreign earned income exclusion.  IRS recently released a fact sheet (FS-2016-22) describing the foreign earned income exclusion and how to claim it a month ago.  IRS also had a free webinar on foreign earned income exclusion for U.S. taxpayers residing in foreign countries on June 29.  The webinar recording will be available later on the IRS website (www.irs.gov).  The IRS technical specialist for the International Individual Compliance unit that I spoke with at the Tax Forum last week could not emphasize more that the Internal Revenue Service finds the foreign earned income exclusion requirement misunderstood by the taxpayers and as a result wants to educate and bring into compliance U.S. residents living abroad.

Please feel free to email me your questions regarding foreign earned income exclusion at jurate.gulbinas@csttax.com.

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Disclaimer:
This document is intended as an information source only. The comments and references to legislation and other sources in this publication do not constitute legal advice and should not be relied upon as such. You should seek advice from a professional adviser regarding the application of any of the comments in this document to your fact scenario. Information in this publication does not take into account any person’s personal objectives, needs or financial situations. Accordingly, you should consider the appropriateness of any information, having regard to your own objectives, financial situation and needs and seek professional advice before acting on it. CST Tax Advisors exclude all liability (including liability for negligence) in relation to your reliance in this publication.

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Expat Blog Post Featuring John Marcarian

Jurate Gulbinas   |   17 Jul 2015   |   2 min read

Leading expat social network Expat-blog.com has recently posted an article about John Marcarian and his experiences as an expatriate.

In the article John talks about important issues such as establishing the CST Singapore office, finding the right accommodation, settling in to the Singaporean lifestyle and how Expatland the book can help soon-to-be expatriates.

Specially designed for those living or wishing to live abroad, Expat blog provides you information and advice to settle and live overseas.

Expat blog helps you throughout your project. Discover life in your host country, get in touch with the other expats and find all the info needed for your everyday life.

To read the article, visit the Expat Blog site on www.expat-blog.com or click on the link http://www.expat-blog.com/en/interview/426_john-in-singapore.html

Download our eBook “Moving To The US”

Disclaimer:
This document is intended as an information source only. The comments and references to legislation and other sources in this publication do not constitute legal advice and should not be relied upon as such. You should seek advice from a professional adviser regarding the application of any of the comments in this document to your fact scenario. Information in this publication does not take into account any person’s personal objectives, needs or financial situations. Accordingly, you should consider the appropriateness of any information, having regard to your own objectives, financial situation and needs and seek professional advice before acting on it. CST Tax Advisors exclude all liability (including liability for negligence) in relation to your reliance in this publication.

NEED ASSISTANCE FOR YOUR SITUATION?

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By providing us your information you agree to our privacy policy

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Australian Budget 2015

Jurate Gulbinas   |   13 May 2015   |   2 min read

On 12 May 2015, the Treasurer Mr Hockey handed down the 2015-16 Federal Budget. The Budget Papers predict a deficit of $35bn next year, down to a $6.9bn deficit in another 3 years’ time in 2018-19.

From a taxation point of view, the Budget contained some important changes relevant to our clients in the area of small business and residency. Other reforms included well publicized changes in relation to taxation of multinationals.

Click here to read the highlights.

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Disclaimer:
This document is intended as an information source only. The comments and references to legislation and other sources in this publication do not constitute legal advice and should not be relied upon as such. You should seek advice from a professional adviser regarding the application of any of the comments in this document to your fact scenario. Information in this publication does not take into account any person’s personal objectives, needs or financial situations. Accordingly, you should consider the appropriateness of any information, having regard to your own objectives, financial situation and needs and seek professional advice before acting on it. CST Tax Advisors exclude all liability (including liability for negligence) in relation to your reliance in this publication.

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2015 Budget Brief – Australian Chamber of Commerce in Hong Kong

Jurate Gulbinas   |   4 May 2015   |   2 min read

Join us at AustCham’s Federal Budget Brief to hear from an expert line up of speakers who will discuss the implications of the 2015-16 Federal Budget.

This seminar will include a review of the highlights of the budget – the good, the bad and the ugly, as well as the major impacts on tax payers and expats specifically. It will also cover the tax issues surrounding expats who plan to return to Australia, including the key points to consider when making the move and effective tax strategies.

About the speakers:
John Marcarian   CEO, Founder of CST Tax Advisors
John is a highly experienced accountant and Tax Advisor whose passion is to serve global expats. He has over 25 years’ experience in international taxation and is a sought after speaker on tax and business matters. John is also the author of Expatland.

Simon DePaoli   Tax Director of CST Tax Advisors Hong Kong
Simon’s focus is to provide International taxation advice for high-net wealth individuals looking to depart and to return to their home country, asset protection and family structuring including Hong Kong company setup and incorporation.

Ato Cheng   Director, International Clients of ABN AMRO
Ato joined ABN AMRO Private Bank N.V. Hong Kong in April 2014. Before joining ABN AMRO, Ato was an Associate of ANZ, Singapore. She has a Bachelor of Commerce from the Curtin University, Australia and an IBFA in Singapore.

Date:
Thursday, 14th May 2015, 6:00pm

Venue:   
AustCham Business Centre
3/F, Lucky Building, 39 Wellington Street, Central

To register for this event please click here.

Download our eBook “Moving To The US”

Disclaimer:
This document is intended as an information source only. The comments and references to legislation and other sources in this publication do not constitute legal advice and should not be relied upon as such. You should seek advice from a professional adviser regarding the application of any of the comments in this document to your fact scenario. Information in this publication does not take into account any person’s personal objectives, needs or financial situations. Accordingly, you should consider the appropriateness of any information, having regard to your own objectives, financial situation and needs and seek professional advice before acting on it. CST Tax Advisors exclude all liability (including liability for negligence) in relation to your reliance in this publication.

NEED ASSISTANCE FOR YOUR SITUATION?

Contact us today
Contact Us
By providing us your information you agree to our privacy policy

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10th Mar 2020
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