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discussing legal aspects related to Taxation.




Tax Evasion: Risk of Discovery Increases – Amended Tax Return as a Way Out

  October 14, 2014     By GRP Rainer LLP
It is becoming increasingly difficult for tax evaders to remain undetected due to the automatic exchange of information between EU member states, particularly as Switzerland has signalled its willingness to cooperate.

Unpaid Income Tax Establishes Liability of the Managing Director of a German Limited Liability Company

  October 9, 2014     By GRP Rainer LLP
In terms of the overall responsibility, a managing director is also liable for the income tax of employed workers that is not paid to the tax office.

Amended Tax Return: North Rhine-Westphalia Wants to Continue Purchasing CDs on Tax Evaders

  October 8, 2014     By GRP Rainer LLP
North Rhine-Westphalia’s (NRW) Minister of Finance, Walter Borjans, announced in the Rheinischen Post Online that NRW will continue purchasing CDs with data on suspected tax evaders.

Tax Evasion: Number Of Amended Tax Returns Has Doubled in Germany

  October 6, 2014     By GRP Rainer LLP
The number of amended tax returns in cases of tax evasion continues to rise. According to media reports, it doubled in the first half of the year 2014 compared with the same period of the previous year.

Tax Evasion: Exercise Caution in the Event of Illicit Earnings in Estate

  October 1, 2014     By GRP Rainer LLP
In the case of inheritance, there is a risk of becoming guilty of tax evasion, particularly if the estate could include illicit earnings.

The Latest Tax Amnesty in Turkey: Law No 6552

  September 30, 2014     By Herdem Attorneys at Law
Turkish parliament has enecated the Law No: 6552 that has been promulgated as of September 11, 2014 and provides restructuring for unpaid tax debts and administrative penalties.

Tax Evasion: Return to Legality via Amended Tax Return

  September 22, 2014     By GRP Rainer LLP
Tax evasion has represented a lucrative, albeit criminal, business not only for tax evaders but also some banks. An amended tax return can present a path to legality.

Tax Evasion: Remain Unpunished By Submitting An Amended Tax Return - Germany

  September 15, 2014     By GRP Rainer LLP
Tax evasion is a criminal offence which not only entails heavy financial penalties, but also custodial sentences. By submitting an amended tax return, you can obtain an exemption from punishment.

Particularities of Inheriting and Bequeathing in Cases Involving a Foreign Element

  August 21, 2014     By GRP Rainer LLP
All states have their own inheritance laws. In succession cases involving a foreign element, the question arises as to which inheritance law is applicable. In many cases, this is a complex matter.

Inheritance Tax: Are Tax Concessions for Businesses Toppling?

  August 20, 2014     By GRP Rainer LLP
The German Federal Constitutional Court (Bundesverfassungsgericht) is currently dealing with inheritance and gift tax. The focus is the question of whether tax benefits for businesses are justified.

Illicit Earnings In Estate: Heirs Must Be Careful – Voluntary Declaration

  August 19, 2014     By GRP Rainer LLP
Nasty surprises can be a risk in the case of inheritance, particularly if an estate includes untaxed illicit earnings. Heirs must be careful.

2014 Amendments to the Malta Retirement Programme Rules

  August 18, 2014     By CSB Advocates
Legal Notice 269 of 2014 has amended the Malta Retirement Programme Rules which were originally promulgated in 2012.

Malta Residence Programme Rules 2014

  August 13, 2014     By CSB Advocates
By virtue of two legal notices published on the 8th of July, the High Net Worth Individuals Rules (HNWI Rules) have now been amended to reflect the Global Residence Programme threshold, both in terms of tax and property value (be it purchase or lease), and a new special tax status is presented.

Saving On Inheritance Tax

  August 13, 2014     By GRP Rainer LLP
In the event of inheritance, the state generally cashes in on inheritance tax, yet money can also be saved with respect to this tax.

Romanian Tax Designated Inactive Companies

  July 28, 2014     By Hammond, Bogaru & Associates
Recently, on 18 July 2014 Order no. 1847 was issued by the President of the National Agency for Fiscal Administration to cover the approval of the application and the forms to be used by inactive taxpayers.

Cyprus Holding Companies

  July 27, 2014     By Anastasios Antoniou LLC
Cyprus provides an established, stable and solid legislative framework under which Cyprus companies can be formed for intermediary or ultimate holding purposes within corporate groups, in project finance, cross-border transactions or even investment management contexts.

Good News for Cayman Domiciled Private Equity Funds - Introduction of New ELP Law

  July 22, 2014     By Loeb Smith & Brady
The Cayman Islands (“Cayman”) continue to be the leading offshore jurisdiction for the establishment of both hedge funds and private equity funds. Typically, private equity funds are structured in Cayman as exempted limited partnerships (“ELPs”) and the introduction of the Exempted Limited Partnership Law, 2014 (the “New ELP Law”), which came into force on 2nd July 2014, will enhance the attractiveness of Cayman as the leading offshore jurisdiction for private equity funds.

China Taxation - New VAT Rate For Biological Products

  By MMLC Group
This article looks at the reasons behind the newly announced reduction in VAT for biological products by the Chinese government.

FATCA - Malta on the Way to Implementing its IGA

Following the signature of the intergovernmental agreement (“IGA”) between Malta and the US on the 16th December, 2013 whereby the latter agreed to implement Foreign Account Tax Compliance provisions (commonly known as FATCA) in Malta, the Inland Revenue Department (“IRD”) has issued draft FATCA Regulations and Guidelines implementing the said intergovernmental agreement.

Willfulness and the Civil FBAR Penalty

  By Brown, PC
In 2008, when it was revealed that wealthy individuals around the world were utilizing accounts and trusts in Liechtenstein to evade taxes, the United States initiated a coordinated effort with foreign governments to combat tax evasion through the use of offshore trusts and accounts. The U.S. Department of Justice (DOJ) has since launched criminal investigations of several foreign banks, many of which are ongoing.

Taxation trends in the European Union in 2014

The Statistical Office of the European Union (Eurostat) and the European Commission's Directorate-General for Taxation and Customs Union has issued a detailed statistical and economic analysis of the tax systems of the Member States of the European Union, which presents an overview of the tax system in each of the 30 countries covered (EU countries, Iceland and Norway), the revenue trends and the main recent policy changes.

Liability of the Shareholder for Public Debts under Turkish Law

Tax Liability in Joint Stock (“Anonim Şirket”) Companies As it has been known, administration and representation of joint stock companies are carried out by board of directors of the company.

IRS Changing Terms for Offshore Account Holders

  By Brown, PC
U.S. taxpayers hiding assets abroad should take note of the Internal Revenue Service’s plan to sharply increase penalties for such acts, while those who unintentionally fail to disclose offshore accounts will experience much more leniency.

Part-Time Self-Employed Tax Submission in Malta

The form for the submission for tax purposes of part-time, self-employed individuals has been amended by virtue of Legal Notice 186 of 2014 [Part-Time (Forms of Self-Employed) (Amendment) Rules, 2014], therefore replacing the previous form in toto.

Tax on Legal Corporations in Costa Rica

Corporation taxes came into force on April 2012, which applies to all legal entities that are duly registered in the Costa Rican Public Registry (e.g. “S.A.”, “LTDA”, among others), as well for those corporations that are in the process of being registered or that will be registered in the future.

Extra! Extra! Read All About It! IRS Commissioner Announces That Changes Are In the Offing For OVDP 2012

On June 3, 2014 the new IRS Commissioner, John A. Koskinen, gave a speech before the International Business - OECD International Tax Conference. His speech covered the history of the offshore enforcement initiative since the UBS debacle in 2009. His remarks acknowledge what most professionals in the tax community have recognized since the inception: that OVDP needs more tweaking in order to meet the overall goals of enforcement and fairness.

U.S. District Court Upholds Multiple Willful FBAR Penalties Against Taxpayer

  By Brown, PC
In a case that has raised eyebrows in the tax community, a jury in the Southern District of Florida has sustained the IRS’s assessment of multiple willful FBAR penalties against an American business man and bank director.

Alphabet Soup for Installment Agreements

What is an installment agreement? An installment agreement is an option for those who cannot pay their entire tax bills by the due date. It allows taxpayers to pay the amount due over a period of time

US Persons with Secret Bank Accounts in Switzerland

In case you have a secret account in Switzerland with a Swiss bank, if you are a US person, if you have received a letter from a Swiss bank demanding to waive your rights to have bank secrecy, is a good idea if you start to act proactively. You can qualify for the OVDP or you file a late FBAR. It is worth to analyse this complex topic on a case-by-case basis.

U.S. to Ease Initial Enforcement of FATCA (Foreign Account Tax Compliance Act)

  By Brown, PC
With FATCA set to take effect on July 1, financial institutions around the world have been lobbying to delay implementation of the law, citing concerns about costs and potential disruptions to global markets.

The Shifting Landscape of the OVDP Opt-Out

  By Brown, PC
Since the IRS announced the 2009 Offshore Voluntary Disclosure Program (OVDP) over five years ago, our firm has been assisting taxpayers submit accurate and complete disclosures in accordance with the program guidelines and procedures. The evolution of the OVDP through the 2011 and 2012 programs has brought a longer look-back period, steeper penalties, and more insight into IRS positions and procedures at different points in the program.

FBAR and FATCA – Two Abbreviations That Can Wrap You Around the IRS Axle

FBAR and FATCA are two important abbreviations for those who have overseas financial interests. Failure to file the FBAR report, in view of the IRS’s continuing application of FATCA, can get you into what old military veterans used to call FUBAR.

Deconstructing the “Act of Production” Doctrine

Tax cases are document-intensive cases. As any white-collar criminal defense attorney knows all too well, summonses and grand jury subpoenas routinely seek documents. And there is a good reason why. If the government cannot get the requested documents, it often cannot make a case. It is for this reason that the seminal issue in document production cases is whether the taxpayer has a Fifth Amendment privilege with respect to documents that he possesses.

The Rules Governing Taxation of Foreign Nationals

Below are the rules governing taxation of foreign nationals.

Starting a Business in Azerbaijan

Some of the legal issues that a person starting business in Azerbaijan would need to consider. This article covers corporate registration, tax and employment aspects of starting and operating business in Azerbaijan.

Company Formation in Albania - Business Licensing

Foreign nationals are entitled to take up economic activities in Albania as self-employed persons, and to set up undertakings, in particular companies, which they effectively control. Foreign companies can also do business in Albania through setting up subsidiaries and branches.

Newest Legal and Tax Implications When Purchasing Real Estate in Spain

In real estate transactions in Spain it still happens more often than not that acquired objects or extensions have to be dismantled because renovations or extensions were not properly authorised or the authorisation was not registered with the different agencies involved. Subsequent permits are possible in some cases, but they do require a special process and incur substantial expenses.

Fraud Technical Advisors: An End-Run Around Tweel?

United States v. Tweel is the most famous example of a motion to suppress in a tax case. In Tweel, the Fifth Circuit Court of Appeals held that it constitutes trickery, fraud, and deceit for the IRS to conduct a criminal investigation under the guise of a civil examination. Because of how fact-sensitive the holding of this case is, a recitation of the facts is necessary.

Cyprus Investment Firm (CIF)

A Cyprus Investment Firm (CIF) is one of the most useful tools in the European Union (and Internationally) if you intend to provide and perform investment services and activities either within Cyprus or abroad on a professional basis on certain financial instruments.

“FATCA” Law is Striking Fear into Foreign Banks

Law That May Reduce Tax Evasion Goes Into Effect On July 1 The Foreign Account Tax Compliance Act (FATCA) became law in the United States in 2010, but the clock is still ticking on its implementation. The clock will stop ticking on July 1, 2014.

What Can A Tax Attorney Do For Me?

Of the professionals that you can turn to for help with IRS problems, tax attorneys can most effectively help you sort through legal issues. Hiring such an expert is the most efficient way of getting on the right track. Here are seven reasons that make them valuable and indispensable.

Ten Ways To Avoid Becoming a Guest of “Club Fed”

Contrary to popular belief, the IRS doesn’t want to throw you in jail. Criminal investigations consume a lot of resources, take time, and are expensive. For most taxpayers, a criminal investigation isn’t a first step, but rather the last step in a lengthy process to get you to resolve your tax debt. In other words, it’s rare that an agent will show up on your doorstep one day with cuffs in hand.

Understanding the PFIC Rules Without Suffering a Migraine

The PFIC regime was not introduced until 1986. Prior to 1986, U.S. taxation of foreign corporations was strictly tied to control of the corporation held by U.S. persons. This allowed not only the foreign mutual fund to avoid U.S. taxation, but also U.S. persons who invested in the fund. How so?

Lifting the Veil on the Civil FBAR Penalty

It should come as no surprise that the IRS has authority to assess FBAR civil penalties. However, what might come as a surprise is that an FBAR violation doesn’t automatically mean that a penalty will be asserted. Why not?

No Laughing Matter: The Criminal Consequences of Failing to Report Foreign Bank Accounts

United States citizens, residents and other persons must annually report their direct or indirect financial interest in, or signature authority over, a financial account that is maintained with a financial institution located in a foreign country if, for any calendar year, the aggregate value of all foreign accounts exceeded $ 10,000 at any time during the year.

Don't Get Snared in Any of the Three Stages of Money-Laundering

Law enforcement and financial regulators everywhere are on the lookout for money laundering. Big corporations and financial institutions hire compliance experts, and those experts cooperate fully rather than face huge fines and penalties.

Liens and Levies Make the IRS a Collection Agency on Steroids

Sometimes the problem with “food for thought” is that it can almost choke you with its stark simplicity. Take our tax system, for example. The federal government prints our money, regulates the places where we keep it and has vast powers to take it away from us if we don’t give them their cut.

Add the Letter ‘T’ to FATCA, and No One’s Getting Fat Except the IRS

In 2010 President Obama signed P.L. 111-147, the Hiring Incentives to Restore Employment Act. The purpose of the law is in its eponymous title, but the IRS got into the act with the Foreign Account Tax Compliance Act (FATCA) provisions.

A Primer on the Foreign Earned Income Exclusion

Ordinarily, the United States taxes U.S. citizens and resident aliens on their worldwide income, even when they live and work abroad for an extended period of time. To provide some relief, a U.S. citizen or resident who meets certain requirements can elect to exclude from U.S. taxation a limited amount of foreign earned income plus a housing cost amount. A double tax benefit is not allowed, however, and a taxpayer cannot claim a credit for foreign income taxes related to excluded income.

IRS Due Process Collections - Placing a Velvet Glove on the Wrecking Ball

Due process is, according to Black’s Law Dictionary, “a course of legal proceedings … which have been established … for the enforcement and protection of private rights.” Anyone facing an IRS federal tax lien or levy has already experienced the preliminary due process following the IRS determination that more taxes are owed.

Internet Enables Thieves to Steal $4 Billion in Tax Refunds

Criminals are utilizing their Internet connection to file false tax returns that help them steal refunds from the innocent. In 2013, fraudulent returns saw almost $4 billion sent into the hands of scam artists. Making things worse is the fact that the Internal Revenue Service is having a hard time stopping the fraud from happening in the first place.

Tariff Disputes in Turkey and Alternative Methods for Resolution

Customs duties can be examined within the scope of two types of taxes which are expenditure tax and excise (Indirect) tax. Customs duty can be described as an expenditure tax. Expenditure taxes are for the services and goods produced sold or consumed. Customs duties are type of excise (indirect) tax as well because taxpayers reflect custom duties to consumer by including the tax into the prices of the goods to be sold. Taxable event, time and who to bear are not certain.

European Commission Tightens Key EU Corporate Tax Rules

The European Commission has put forward certain amendments to key EU corporate tax legislation, in order to significantly reduce tax avoidance in Europe. The proposal will address deficiencies in the Parent-Subsidiary Directive, which may allow the operation of structures that will benefit from reduced taxation.

The Taxation Perspective in Liquidiation of Turkish Companies

As well as the company establishment, an investor may take decision for termination of his/her company or a company's termination conditions stated in the laws may occur such that start of a liquidation process becomes unavoidable for the company.

Fighting The Post-Bankruptcy Survival Of Federal Tax Liens On Property Excluded From The Bankruptcy Estate

The federal tax collection system is founded on the concept of voluntary compliance.[1] The United States government expects taxpayers to compute and timely pay all taxes owed. Most taxpayers fulfill this obligation. However, a minority refuse to comply. Those falling within the latter category are subject to forced collection and various penalties.

Obtaining a Residence Permit in Greece

Greek government instated a procedure to obtain permanent residence permits, which can be renewed every five years, for third-country citizens who own real estate in Greece of minimum value €250.000, adopting a friendlier stance towards those who wish to own real estate property in Greece.

The Greek Real Estate Market for Foreign Investors

Our practical guide to real estate in Greece covers the entire spectrum of legal and tax issues which arise in practice when purchasing, managing, utilizing, developing and reselling property in Greece. It is addressed to both Greek nationals and foreign citizens of other European and non-EU countries who have a practical interest in legal and tax matters in Greece, with the aim of facilitating entrepreneurship and more generally the access of foreigners to the Greek market.

Think You Got Game? Try Solving a Criminal Tax Problem

While reading can aid in learning, there is no substitute for doing. Reading about what steps should be taken to solve a tax problem is no different than reading about how to ride a bicycle. In the same way that the only way to learn how to ride a bicycle is by experiencing it firsthand – i.e., by physically getting on it (and perhaps falling off it more than once) – the only way to become proficient at solving tax problems is by trudging through a multitude of hypotheticals.

Income Tax Act, 1962 : Section 12L

As part of an initiative to become more energy efficient, the South African Government has decided to incentivise reductions in energy usage. Coming into operation on 1 November the recently introduced section 12L of the Income Tax Act, No 58 of 1962 (‘the Act’) provides for a tax deduction calculated by a set formula pertaining to the amount of energy saved for any person that is carrying on a trade during any year of assessment ending before 1 January 2020.

New Amendment to the Highly Qualified Persons Rules - Malta

Legal Notice 16 of 2014, has brought into effect amendments to the Highly Qualified Persons Rules, applicable retrospectively from year of assessment 2013.

More U.S. Taxpayers Admit to Secret Swiss Accounts

Why Swiss Bank Clients Who Can’t Stand the Heat Are Getting Out of the Kitchen.

Failing to File a Tax Return and that “Wascally” Little Word (not "Wabbit") Called Willfulness

Nary a day goes by that a client doesn’t ask me the question, “Why am I being charged criminally with failing to file my tax returns? Lots of people get behind on their taxes and fail to file their returns for a few years, but they are not prosecuted. Why me?”

Home Sweet Home for International Tax Collection

Recently, I received a panicked call from a client being detained at a major metropolitan airport. The client, a nonresident U.S. taxpayer, owed money to the Internal Revenue Service. Upon investigation, I learned who was responsible for detaining him: none other than the IRS. Under what authority? A two-year-old program designed to target nonresident delinquent taxpayers who travel to and from the United States.

Don’t Forget to Add the Salt When Cooking Up an IRS Voluntary Disclosure

New Jersey Notice of Federal Tax Change Requirements

Section 6050I – A Weapon In The IRS’s Criminal Arsenal

Congress enacted section 6050I to attack and unearth the underground economy. As enforced, however, section 6050I has been used as a weapon in the IRS’s criminal arsenal.

Long-term Investment Account - Hole in the Net

The purpose of the personal income tax is to make Hungarian tax residents liable to tax on all their personal income irrespective of where the income is sourced and in which form it is realized. The personal income tax laws, therefore, create a net around the individuals and any item of income can only get through the net if it has been taxed.

New Jersey Clamping Down on Tax Evasion Amongst Small Business Owners

The Internal Revenue Service takes great pleasure in auditing individuals who own their own small businesses. Why target these “moms and pops?” For the simple reason that they often deal in cash and keep two sets of books. Add in possible sales tax violations and before you know it auditors from the state revenue department have joined in the action.

Rescued From the Brink of Insanity: Practical Advice for Making the Decision to Opt Out of the OVDI - Part II

Hypotheticals demonstrating when opting out is detrimental to the taxpayer.

Rescued From the Brink of Insanity: Practical Advice for Making the Decision to Opt Out of the OVDI - Part I

Opting Out: The solution for the non-willful OVDI taxpayer? Hypotheticals demonstrating when opting out is in the best interests of the taxpayer.

Argentina: Tax Havens - Publication of the List of Cooperative Jurisdictions for Tax Transparency Purposes

The National Tax Authority (“AFIP”) published today in its “web” site the list of countries, jurisdictions, territories, states and special tax regimes which qualify as cooperative for tax transparency purposes (the “Cooperative Jurisdiction List”).

The Current Account Deficit and The Tax Increases in Turkey

The unprecedented level of economic growth in Turkey during the last decade have created an economy with a GDP person of USD$ 10.000, an inflation rate cut down below the double digits, a purchasing power more than quadrupled, capacity utilization ratio of 75.6%, a government budget deficit below the Maastricht criteria of 3% and a public debt to GDP reduced down to 36% of the GDP.

Tax Advantages in Turkey: R&D

In line with its high economic growth and its transformation in to an economic hub in its region, Turkey is recently investing alot to transform itself in to a center of high tech and R&D.

Tax Haven and Legislation in Turkey

I. INTRODUCTION Turkey has been trying to take the strong measures against tax havens and monies left to these countries, but the measures still seem not enough. In order to understand this, foreign investors’ tendency and applicability of Turkish laws should be examined.

A Tax Exempt Start up for Multinational Companies: Liasion Offices in Free Trade Zones of Turkey

Today, in global cash flow around the world made multinational companies to think more on tax benefits and cost effectiveness before they invest in a country.

On Transfer Pricing by Permanent Representative Offices of Non-resident Pharm Companies - Ukraine

The problem of taxation of permanent representative offices of non-residents (including multinational pharmaceutical companies) has recently gained considerable importance, not least of all due to the attempts on behalf of the tax authorities to make such permanent representative offices pay the taxes in Ukraine. Such attempts of the tax authorities have several times been backed up by the courts, thus the debate to define the “tax nature” of representative offices has become a pressing issue.

Don't Gamble With Gift Tax Returns

Beginning in 2011, the IRS started cracking down on taxpayers who did not file gift tax returns after making gifts that required reporting.

Think You Got Game? Try Being like Santa. How Imitating Santa Can Help You Save Taxes This Year

Paying tax is painful. But reading about it shouldn't be.

Immediate Tax Deducts for Accrued Property Transfer Taxes – Germany

Whether real estate is being acquired entirely new in the context of property acquisition or if it was already in the partnership’s possession is an important fact.

Italian Parliament Approves ‘Google Tax’ in 2014 Budget but the European Union Thinks It Is Illegal

Italy’s Parliament approved a controversial law on Friday forcing tech giants like Google to sell advertising online only through Italian intermediaries, provoking anger from digital economy experts.

Chinese Regulations for Investments in Germany

A rather detailed introduction of the legal aspects of outbound investment from China to foreign countries based upon the legal reality of China before 2012, which is undergoing further major changes in China at the moment.

Four End of the Year Ideas to Save Money on Your Taxes

  By HG.org
For millions of Americans, the holiday season is about giving and charity, and few stop to consider the state of their personal finances and taxes. But, the end of the year is also the end of a tax period for individuals, meaning that come December 31, they cannot make any more changes that will help reduce the taxes they will have to pay in a few months.

New Jersey Estate & Inheritance Tax: Reducing the Size of the Estate Through Gifting

New Jersey is one of only a few states that impose both an inheritance tax and a state estate tax. The inheritance tax applies when someone who lived in New Jersey, or owned property there, leaves property to someone who isn’t a close relative. The tax rate depends on how closely the inheritors and deceased person were related.

New Jersey Estate Tax: The Uninvited Guest

New Jersey collects both an inheritance tax and its own estate tax, separate from the federal estate tax.

Is There Any Tax Liability for Giving a Gift?

  By HG.org
Those who have dabbled with tax laws much at all are probably familiar with the general mantra that any money received may be taxable income. They may also be familiar with the idea that payments over a certain amount or in certain types of relationships (like employer/employee) often require that the payer ensure taxes are taken out before the balance is given to the payee. But what about gifts? Is there any tax liability for giving a gift?

Foreign Account Tax Compliance Act - Panama

In 2014, essentially all the financial institutions operating in Panama will be required to submit information to the United States (IRS) authorities, concerning “American citizen” in Panama.

How Does U.S. Law View Offshore Bank Accounts?

  By HG.org
Perhaps you are one of the fortunate few who has achieved a level of wealth where you are legitimately concerned that the ebb and flow of the U.S. economy could have a dramatic effect on your personal finances. Or, perhaps, you have heard that there are ways to avoid certain taxes if you keep your money offshore.

A Message from Uncle Sam to Taxpayers Who Have Undisclosed Foreign Bank Accounts: the Clock Is Ticking

OVDI: Is the IRS playing unfair? Read on...

Found Money – What Are My Legal Obligations?

  By HG.org
Everyone has seen a few cents on the ground, likely dropped while someone pulled a ring of keys from their pocket. While we would probably not think twice about picking up a penny, what if it was a bank envelope full of $100 bills? It may seem like a dream come true, but there are certain legal obligations when one finds misplaced money.

Can Foreigners Buy Real Estate in the United States?

  By HG.org
As the real estate market in the U.S. has made a strong indication of recovery, some outside of the United States have begun to look again at American real estate investments as a possibility. This leads some to wonder, though, whether it is even possible for a foreigner to buy real estate in the U.S.? If so, are there any special laws to be aware of or taxes that must be paid?

The Calm Before the Storm: Warning Signs that a Referral to Criminal Investigation is Looming

A criminal investigation conducted by the IRS is different from a civil investigation. Criminal investigation of taxpayer returns or fraudulent activity is conducted by the Criminal Investigation Division of the IRS (CI). CI is the heavy artillery of the IRS arsenal.

Eggshell Audits: Keeping the Shell of the Egg From Cracking When There are Criminal Tax Issues

In an “eggshell audit,” you must walk on eggshells to represent your client effectively in the civil examination without exposing the fraud, all the while honoring your duties to the tax system not to mislead the revenue agent.

To File or Not to File an Amended Return to Correct an Original Return That Has Criminal Tax Dimensions

Your client has filed a fraudulent return underreporting his tax liability. He now has misgivings. He comes to you and expresses great concern. What should you do?

The Hazards of Failing to File a Tax Return

All of us procrastinate. But some take things to dangerous extremes – putting off the filing of tax returns for a few years, or even many years. According to the IRS, each year some ten million people fail to file their tax returns. Nonfilers, as the IRS calls them, are skating on thin ice. They face both criminal and civil consequences. Luckily, these problems can be resolved if addressed, but they can also bring imprisonment and financial ruin if ignored.

New Facilities for Customs Clearance in International Trade

New regulations in Turkish International Trade Law came into effect on 10.01.2013 in order to simplify customs procedures for international traders. With the new regulation, economic operators can apply for an Authorized Economic Operator (AEO) status, which is given permanently with no expiry, either to have easier access to customs simplifications or to be in a more favorable position to comply with the new security requirements.

Whistleblowers Programs Could Help Regain Funds From Tax Dodgers

According to the California Franchise Tax Board, the state is owed more than 6.5 billion dollars in tax revenue. Some contend that implementation of a whistleblower rewards program could help to bring in some of that lost revenue.

Malta – Liechtenstein Doble Taxation Treaty

Malta's continuous effort in extending its tax treaty network (nearly 70 treaties entered into by Malta up to the end of October 2013) is again evidenced by a new tax treaty signed with Liechtenstein.

Updated Article Life in the Sun: The Ease of Benefitting from Tax Residence in Malta

Further to the suspension of the Permanent Residents Scheme in December 2010, the Government of Malta has put in place a scheme for special tax status aimed at attracting internationally mobile, high net worth individuals (HNWI) to become tax resident in our islands and benefit from a favorable tax rate of 15% on any income remitted into Malta.

The Migration of Non Resident Trusts to Italy

Trusts are still alien to the Italian legal system as they are essentially based on concepts in contrast with the Italian general principles on ownership. As the Italian legal system does not have a definition of trust, the Hague Convention has provided one, together with rules to be applied by Italian judges in the presence of conflicts in case of assets in trust located in Italy.

Polish and Turkish Legal Systems for Value Added Tax (VAT)

The value added tax (VAT), is a type of indirect turnover based tax that is levied during the final phase of the purchaser of the goods and is included in the price of the purchased item or service. Being a turnover tax, VAT is levied at each stage of the production and the distribution process as well.

Tax Deductibility of Valuation Reports in Divorce Proceedings – Germany

When assessing the value of a property because of the duty to disclose information and pay gains in divorce proceedings, the costs incurred are not tax deductible.


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