1) The document discusses the tax implications of transferring real estate properties to a trust in Israel. It notes that transferring properties to a trust for beneficiaries who are not the owners would be considered a taxable event under Israeli real estate tax law.
2) An example is provided of parents transferring two apartments to their daughters through a trust to receive tax benefits. Establishing the trust allows the transfer to be considered a tax-exempt gift and reduces the applicable purchase tax.
3) The document also discusses using a trust structure to potentially reduce tax rates on interest income from loans to companies. Placing loans in a trust could allow interest to be taxed at standard rates rather than higher marginal rates that would apply to direct loans
Trusts Tax Planning Risks and Opportunities artzihiba
- An Israeli resident settlor created a trust in a foreign treaty country, with Israeli resident beneficiaries.
- The trust income is taxed in Israel as income of an Israeli resident, however grants to the trust and distributions from it are not taxed.
- Israel can tax income earned in Israel by the foreign resident trust, and may have limited taxation rights on certain types of Israeli-source income based on the relevant tax treaty.
This document discusses tax exemptions and reliefs for returning residents and new residents to Israel. It provides definitions for regular returning residents, long-term returning residents, and new residents. It summarizes the key exemptions and reliefs for long-term returning residents and new residents, including a 10-year exemption on income from outside Israel, not having to report foreign assets or income, and exemptions applying to new activities outside Israel. It also compares the exemptions for regular versus long-term returning residents. The document discusses two recent court cases that impacted the interpretation of residency and implications for splitting the family unit. It concludes with information on taxations that may apply to Israeli beneficiary trusts depending on the settlor's alive
This document discusses tax planning opportunities and risks related to trusts. It describes risks such as trusts becoming taxable as Israeli trusts after the settlor returns to Israel as a resident. It also describes opportunities such as using trusts to inherit losses or take advantage of the Israeli tax status of trusts. The document provides examples and analysis of relevant sections of Israeli tax law.
סופי מצגות ג'נבה וציריך - 25-25 בנובמבר 2014artzihiba
This document summarizes the presentation "Regularization of Undeclared Israeli Assets" given by Hagi Elmekiesse. It discusses voluntary disclosure procedures and settlement options available through the Israeli Tax Authority for regularizing undeclared offshore bank accounts, trusts, and life insurance policies. Key points covered include the risks of non-disclosure, the two-step voluntary disclosure process, costs of settlement which typically range from 5-18% tax on assets, and temporary procedures available for smaller accounts and trusts.
כנס ציריך גילוי מרצון והסדרי נאמנויות 5 2 2014artzihiba
This document discusses voluntary tax disclosure and trust settlements with the Israeli Tax Authority. It provides background on the speaker's qualifications and experience in international taxation and settlements. It outlines the purposes and conditions for voluntary disclosure, including receiving immunity from criminal sanctions and disclosing previously unreported income and assets. It describes the two-step process for preparing an application, which involves gathering documents, analyzing tax exposure, and applying to settle both criminal and civil issues. It also covers considerations for settling foreign settlor trusts and typical tax rates applied in trust settlements based on past experience.
The document discusses the rules of statutory interpretation applied to tax statutes based on a case cited. It provides the background and context for the rules. The key rules discussed are:
1) Words are given their ordinary meaning and courts do not consider consequences of interpretation or imply meanings not clearly stated.
2) Ambiguities or doubts are resolved in favor of the taxpayer.
3) The "golden rule" allows considering consequences to avoid absurdity if the language permits.
4) The "mischief rule" allows considering reasons for legislation to advance its purpose if ambiguity exists.
More recent cases show a shift toward a more purposive approach seeking legislative intent over formalism. Courts now aim to
This document summarizes recent tax law amendments in Zimbabwe. It discusses changes to provisions around related party expenditures, permanent establishments, taxable income attributable to PEs, capital gains tax, classification of goods, and reporting of unprofessional conduct. Key points include broadening the capital gains tax base, classifying goods based on tariff headings and chapter notes, and allowing the tax authority to report professionals for actions aimed at tax evasion.
This document provides an overview of the Israeli tax system and tax benefits available for foreign residents. It discusses key aspects of the Israeli tax system including determining tax residency, tax rates, and international tax rules. It also outlines several tax benefits for foreign residents such as exemptions from capital gains tax, investment income tax, and participation in programs under the Law for Encouragement of Capital Investment.
Trusts Tax Planning Risks and Opportunities artzihiba
- An Israeli resident settlor created a trust in a foreign treaty country, with Israeli resident beneficiaries.
- The trust income is taxed in Israel as income of an Israeli resident, however grants to the trust and distributions from it are not taxed.
- Israel can tax income earned in Israel by the foreign resident trust, and may have limited taxation rights on certain types of Israeli-source income based on the relevant tax treaty.
This document discusses tax exemptions and reliefs for returning residents and new residents to Israel. It provides definitions for regular returning residents, long-term returning residents, and new residents. It summarizes the key exemptions and reliefs for long-term returning residents and new residents, including a 10-year exemption on income from outside Israel, not having to report foreign assets or income, and exemptions applying to new activities outside Israel. It also compares the exemptions for regular versus long-term returning residents. The document discusses two recent court cases that impacted the interpretation of residency and implications for splitting the family unit. It concludes with information on taxations that may apply to Israeli beneficiary trusts depending on the settlor's alive
This document discusses tax planning opportunities and risks related to trusts. It describes risks such as trusts becoming taxable as Israeli trusts after the settlor returns to Israel as a resident. It also describes opportunities such as using trusts to inherit losses or take advantage of the Israeli tax status of trusts. The document provides examples and analysis of relevant sections of Israeli tax law.
סופי מצגות ג'נבה וציריך - 25-25 בנובמבר 2014artzihiba
This document summarizes the presentation "Regularization of Undeclared Israeli Assets" given by Hagi Elmekiesse. It discusses voluntary disclosure procedures and settlement options available through the Israeli Tax Authority for regularizing undeclared offshore bank accounts, trusts, and life insurance policies. Key points covered include the risks of non-disclosure, the two-step voluntary disclosure process, costs of settlement which typically range from 5-18% tax on assets, and temporary procedures available for smaller accounts and trusts.
כנס ציריך גילוי מרצון והסדרי נאמנויות 5 2 2014artzihiba
This document discusses voluntary tax disclosure and trust settlements with the Israeli Tax Authority. It provides background on the speaker's qualifications and experience in international taxation and settlements. It outlines the purposes and conditions for voluntary disclosure, including receiving immunity from criminal sanctions and disclosing previously unreported income and assets. It describes the two-step process for preparing an application, which involves gathering documents, analyzing tax exposure, and applying to settle both criminal and civil issues. It also covers considerations for settling foreign settlor trusts and typical tax rates applied in trust settlements based on past experience.
The document discusses the rules of statutory interpretation applied to tax statutes based on a case cited. It provides the background and context for the rules. The key rules discussed are:
1) Words are given their ordinary meaning and courts do not consider consequences of interpretation or imply meanings not clearly stated.
2) Ambiguities or doubts are resolved in favor of the taxpayer.
3) The "golden rule" allows considering consequences to avoid absurdity if the language permits.
4) The "mischief rule" allows considering reasons for legislation to advance its purpose if ambiguity exists.
More recent cases show a shift toward a more purposive approach seeking legislative intent over formalism. Courts now aim to
This document summarizes recent tax law amendments in Zimbabwe. It discusses changes to provisions around related party expenditures, permanent establishments, taxable income attributable to PEs, capital gains tax, classification of goods, and reporting of unprofessional conduct. Key points include broadening the capital gains tax base, classifying goods based on tariff headings and chapter notes, and allowing the tax authority to report professionals for actions aimed at tax evasion.
This document provides an overview of the Israeli tax system and tax benefits available for foreign residents. It discusses key aspects of the Israeli tax system including determining tax residency, tax rates, and international tax rules. It also outlines several tax benefits for foreign residents such as exemptions from capital gains tax, investment income tax, and participation in programs under the Law for Encouragement of Capital Investment.
As well as assisting individual clients, Ehsan Kabir regularly liaises and consults businesses by providing consultancy, assistance, and advisory services. Contact Ehsan Kabir today regarding any legal concerns you are facing. Ehsan Kabir works effortlessly and tirelessly around the clock to anyone with a legal inquiry. To maintain the high standards of client care Mr. Kabir provides out of hours services as well as Skype consultations and meetings with clients who may be based abroad.
Ehsan Kabir Solicitor is telling about, how to make a will in the United Kingdom? Ehsan Kabir works effortlessly and tirelessly around the clock to anyone with a legal inquiry.
NAVI MUMBAI BRANCH OF WIRC OF ICAI
ICAI Intensive Course on International Taxation
Presentation on Understanding tax treaties & credit for double tax including underlying tax credit
The document discusses recent changes to the Annual Tax on Enveloped Dwellings (ATED) in the UK. The ATED applies taxes to high-value residential properties owned by corporate entities and non-natural persons. Recent changes have lowered the threshold for properties subject to the tax and increased tax rates. This subjects more properties to the tax, including some held by property developers and letting businesses. Filing requirements and available reliefs are also discussed.
EODB INDONESIA 2018 - 2019 - Getting Credit HandbookAydinLemon
Indonesia has progressed significantly in deregulating its economy as its ranking in the Ease of Doing Business (EODB) index for 2018, Further Information : https://www.investindonesia.go.id/en/why-invest/ease-of-doing-business
The document provides a summary of key articles in the OECD Model Convention on Double Taxation Agreements (DTAA). It outlines 30 articles that cover aspects such as persons covered, taxes covered, definitions, residential status, permanent establishment, taxation of various types of income including business profits, dividends, interest, royalties, capital gains, employment income and pensions. The articles also address exchange of information, assistance in tax collection and territorial extension of the DTAA.
The document provides an overview of benami transactions and the Benami Transactions (Prohibition) Act 1988 in India. Some key points:
- Benami means "property without name" and refers to transactions where property is purchased in someone else's name without intending to benefit them.
- The 1988 Act was introduced to prohibit benami transactions and recover properties held benami, as such transactions were previously abused to evade taxes, circumvent land ceilings, and commit fraud.
- Under the Act, benami transactions are prohibited and no suits can be filed to claim rights over benami properties. Benami properties are also liable for acquisition by authorities. However, the Act had deficiencies in implementation and scope
The document compares amendments proposed by the Indian government to the Benami Transactions (Prohibition) Amendment Bill of 2015. Key proposed amendments include narrowing the definition of benami transactions, exempting certain property transfers where stamp duty was paid, and allowing authorized representatives during adjudication proceedings. The Standing Committee on Finance had recommended some of these amendments, including qualifications for the Appellate Tribunal Chairperson. The Committee also suggested addressing unaccounted wealth through income tax laws and digitizing land records instead of a separate benami law.
INTRODUCTION
The Central Bank of Nigeria (CBN), as a major stakeholder in the regulation of Nigerian economy, has joined in the search for a way to save the country’s economy and has come up with a circular to all deposit money banks (DMBs) and other financial institutions in Nigeria, titled “Collection and remittance of statutory charges on receipts to Nigeria postal service under the Stamp Duties Act”. The Circular dated 15th Jan, 2016 was made available to the public on the 19th of Jan, 2016.
The document provides information on arbitration and enforcement of foreign judgments in Kuwait. It discusses:
- International treaties Kuwait has signed related to arbitration and enforcement, including the New York Convention.
- Kuwait's arbitration system being similar to other jurisdictions, using both institutional and judicial arbitration.
- The main arbitration bodies in Kuwait operating under its civil and commercial laws.
- Foreign arbitration decisions and court decisions being recognized based on reciprocity.
- Mandatory procedures that must be followed in Kuwaiti arbitration, including requirements for arbitration agreements.
The document summarizes key aspects of the Benami Transactions (Prohibition) Act in India. It was passed in 2016 to curb black money. Key points:
1) The Act came into force on November 1, 2016. It replaced the previous Benami Transactions (Prohibition) Act of 1988 and renamed it the Prohibition of Benami Property Transactions Act.
2) A benami transaction is one where the actual owner of the property is different than the named owner. It aims to identify transactions done in bogus names or where the real beneficiary is not traceable.
3) Failure to provide PAN details for property transactions over 10 lakh rupees or non-deduction of TDS
The benami transactions (prohibitions) amendment act (1)Himanshu Goyal
The document summarizes the Prohibition of Benami Property Transactions Act of 1988 as amended in 2016 in India. Some key points:
- The act prohibits benami transactions where one person provides consideration for a property but it is held in another person's name. Such properties are liable to be confiscated.
- The 2016 amendment strengthened penalties, setting up adjudicating authorities and an appellate tribunal to deal with benami cases.
- Transactions done for illegitimate purposes like concealing black money or evading taxes come under the purview of benami transactions according to the act.
- Properties involved in benami transactions are liable to face attachment or confiscation and individuals can be fined or imprisoned for
The document discusses the controversy around giving NIPOST the power to collect stamp duty revenue. It argues that doing so stands against logic and the law. The Stamp Duties Act gives collection powers solely to FIRS and states, not NIPOST as it is a federal agency and states should control their own revenue. NIPOST's proposed amendments to make itself the collector were opposed as an unlawful attempt to usurp FIRS's statutory powers.
The document summarizes key aspects of the Benami Transactions (Prohibition) Amendment Act 2016 in India. It defines benami transactions as purchasing or holding property in someone else's name while providing the consideration. The Act aims to prohibit benami transactions and allow for confiscation of benami properties. It establishes authorities like initiating officers, adjudicating authorities, and an appellate tribunal to oversee the attachment, adjudication and confiscation of benami properties. Penalties for offenses include fines up to 25% of fair market value and imprisonment from 1-7 years. The Act is expected to impact the real estate market by reducing black money transactions and property disputes.
This document requests that legal provisions be strengthened to prevent abuse by companies like Kingfisher Airlines. It suggests that if a "nil balance company" does not take action to resolve its affairs for over a month, it should be forced to wind up. Existing laws on lifting the corporate veil and fraudulent trading may also apply. Contracts made with unlawful objects or considerations, like knowingly taking on expenses without means to pay, should be void to prevent harm to employees and investors. Strengthening these laws could help address issues like those seen with Kingfisher Airlines.
This presentation discusses benami transactions in light of demonetization. It begins by highlighting key points of demonetization and the Prohibition of Benami Property Transactions Act of 1988. It defines what constitutes a benami property and transaction, providing examples of cash and stock being considered benami property. Exceptions to benami transactions are outlined, along with impacts such as 100% confiscation of benami property and imprisonment. The presentation explains how benamidars (property holders) and beneficial owners (intended beneficiaries) are impacted under the new Act.
The document discusses the Benami Transactions (Prohibition) Amendment Bill, 2015, which seeks to amend the Benami Transactions Act of 1988. The key points are:
1) The Bill aims to amend the definition of benami transactions, establish authorities to deal with such cases, and specify penalties.
2) A benami transaction is one where a property is held under a false name, with the real owner denying knowledge or being untraceable.
3) Certain exemptions like HUF properties are specified. Penalties for benami transactions and false information are increased.
4) Adjudicating authorities and an Appellate Tribunal will be set up to examine cases and hear appeals against confiscating
This document provides answers to frequently asked questions about property sales in Abu Dhabi. It states that UAE nationals and GCC nationals can own land anywhere in Abu Dhabi and in designated investment areas, while other nationalities can only invest in investment areas. It defines investment areas and musatahas (ground development leases). Common buyer obligations include following use rules and paying service charges. Inherited properties transfer to heirs. Registration fees are 2% of property value or 1% of annual rent. There are no property or rental taxes, and mortgages are available from banks and financial companies. Lawyers are not strictly needed but recommended. Property purchase does not guarantee a residence visa.
The document summarizes key concepts in Philippine real estate law, including:
- Ownership rights include the right to possess, use, enjoy fruits, dispose of, and recover property. Limitations include those imposed by law, contract, taxation, and eminent domain.
- Land ownership extends to the subsurface and airspace. Hidden treasures found on one's land belong to the land owner, with exceptions if found on another's land.
- Ownership rights include rights of accession to property's produce and improvements. Generally, only Filipino citizens and corporations may acquire land, with some exceptions.
As well as assisting individual clients, Ehsan Kabir regularly liaises and consults businesses by providing consultancy, assistance, and advisory services. Contact Ehsan Kabir today regarding any legal concerns you are facing. Ehsan Kabir works effortlessly and tirelessly around the clock to anyone with a legal inquiry. To maintain the high standards of client care Mr. Kabir provides out of hours services as well as Skype consultations and meetings with clients who may be based abroad.
Ehsan Kabir Solicitor is telling about, how to make a will in the United Kingdom? Ehsan Kabir works effortlessly and tirelessly around the clock to anyone with a legal inquiry.
NAVI MUMBAI BRANCH OF WIRC OF ICAI
ICAI Intensive Course on International Taxation
Presentation on Understanding tax treaties & credit for double tax including underlying tax credit
The document discusses recent changes to the Annual Tax on Enveloped Dwellings (ATED) in the UK. The ATED applies taxes to high-value residential properties owned by corporate entities and non-natural persons. Recent changes have lowered the threshold for properties subject to the tax and increased tax rates. This subjects more properties to the tax, including some held by property developers and letting businesses. Filing requirements and available reliefs are also discussed.
EODB INDONESIA 2018 - 2019 - Getting Credit HandbookAydinLemon
Indonesia has progressed significantly in deregulating its economy as its ranking in the Ease of Doing Business (EODB) index for 2018, Further Information : https://www.investindonesia.go.id/en/why-invest/ease-of-doing-business
The document provides a summary of key articles in the OECD Model Convention on Double Taxation Agreements (DTAA). It outlines 30 articles that cover aspects such as persons covered, taxes covered, definitions, residential status, permanent establishment, taxation of various types of income including business profits, dividends, interest, royalties, capital gains, employment income and pensions. The articles also address exchange of information, assistance in tax collection and territorial extension of the DTAA.
The document provides an overview of benami transactions and the Benami Transactions (Prohibition) Act 1988 in India. Some key points:
- Benami means "property without name" and refers to transactions where property is purchased in someone else's name without intending to benefit them.
- The 1988 Act was introduced to prohibit benami transactions and recover properties held benami, as such transactions were previously abused to evade taxes, circumvent land ceilings, and commit fraud.
- Under the Act, benami transactions are prohibited and no suits can be filed to claim rights over benami properties. Benami properties are also liable for acquisition by authorities. However, the Act had deficiencies in implementation and scope
The document compares amendments proposed by the Indian government to the Benami Transactions (Prohibition) Amendment Bill of 2015. Key proposed amendments include narrowing the definition of benami transactions, exempting certain property transfers where stamp duty was paid, and allowing authorized representatives during adjudication proceedings. The Standing Committee on Finance had recommended some of these amendments, including qualifications for the Appellate Tribunal Chairperson. The Committee also suggested addressing unaccounted wealth through income tax laws and digitizing land records instead of a separate benami law.
INTRODUCTION
The Central Bank of Nigeria (CBN), as a major stakeholder in the regulation of Nigerian economy, has joined in the search for a way to save the country’s economy and has come up with a circular to all deposit money banks (DMBs) and other financial institutions in Nigeria, titled “Collection and remittance of statutory charges on receipts to Nigeria postal service under the Stamp Duties Act”. The Circular dated 15th Jan, 2016 was made available to the public on the 19th of Jan, 2016.
The document provides information on arbitration and enforcement of foreign judgments in Kuwait. It discusses:
- International treaties Kuwait has signed related to arbitration and enforcement, including the New York Convention.
- Kuwait's arbitration system being similar to other jurisdictions, using both institutional and judicial arbitration.
- The main arbitration bodies in Kuwait operating under its civil and commercial laws.
- Foreign arbitration decisions and court decisions being recognized based on reciprocity.
- Mandatory procedures that must be followed in Kuwaiti arbitration, including requirements for arbitration agreements.
The document summarizes key aspects of the Benami Transactions (Prohibition) Act in India. It was passed in 2016 to curb black money. Key points:
1) The Act came into force on November 1, 2016. It replaced the previous Benami Transactions (Prohibition) Act of 1988 and renamed it the Prohibition of Benami Property Transactions Act.
2) A benami transaction is one where the actual owner of the property is different than the named owner. It aims to identify transactions done in bogus names or where the real beneficiary is not traceable.
3) Failure to provide PAN details for property transactions over 10 lakh rupees or non-deduction of TDS
The benami transactions (prohibitions) amendment act (1)Himanshu Goyal
The document summarizes the Prohibition of Benami Property Transactions Act of 1988 as amended in 2016 in India. Some key points:
- The act prohibits benami transactions where one person provides consideration for a property but it is held in another person's name. Such properties are liable to be confiscated.
- The 2016 amendment strengthened penalties, setting up adjudicating authorities and an appellate tribunal to deal with benami cases.
- Transactions done for illegitimate purposes like concealing black money or evading taxes come under the purview of benami transactions according to the act.
- Properties involved in benami transactions are liable to face attachment or confiscation and individuals can be fined or imprisoned for
The document discusses the controversy around giving NIPOST the power to collect stamp duty revenue. It argues that doing so stands against logic and the law. The Stamp Duties Act gives collection powers solely to FIRS and states, not NIPOST as it is a federal agency and states should control their own revenue. NIPOST's proposed amendments to make itself the collector were opposed as an unlawful attempt to usurp FIRS's statutory powers.
The document summarizes key aspects of the Benami Transactions (Prohibition) Amendment Act 2016 in India. It defines benami transactions as purchasing or holding property in someone else's name while providing the consideration. The Act aims to prohibit benami transactions and allow for confiscation of benami properties. It establishes authorities like initiating officers, adjudicating authorities, and an appellate tribunal to oversee the attachment, adjudication and confiscation of benami properties. Penalties for offenses include fines up to 25% of fair market value and imprisonment from 1-7 years. The Act is expected to impact the real estate market by reducing black money transactions and property disputes.
This document requests that legal provisions be strengthened to prevent abuse by companies like Kingfisher Airlines. It suggests that if a "nil balance company" does not take action to resolve its affairs for over a month, it should be forced to wind up. Existing laws on lifting the corporate veil and fraudulent trading may also apply. Contracts made with unlawful objects or considerations, like knowingly taking on expenses without means to pay, should be void to prevent harm to employees and investors. Strengthening these laws could help address issues like those seen with Kingfisher Airlines.
This presentation discusses benami transactions in light of demonetization. It begins by highlighting key points of demonetization and the Prohibition of Benami Property Transactions Act of 1988. It defines what constitutes a benami property and transaction, providing examples of cash and stock being considered benami property. Exceptions to benami transactions are outlined, along with impacts such as 100% confiscation of benami property and imprisonment. The presentation explains how benamidars (property holders) and beneficial owners (intended beneficiaries) are impacted under the new Act.
The document discusses the Benami Transactions (Prohibition) Amendment Bill, 2015, which seeks to amend the Benami Transactions Act of 1988. The key points are:
1) The Bill aims to amend the definition of benami transactions, establish authorities to deal with such cases, and specify penalties.
2) A benami transaction is one where a property is held under a false name, with the real owner denying knowledge or being untraceable.
3) Certain exemptions like HUF properties are specified. Penalties for benami transactions and false information are increased.
4) Adjudicating authorities and an Appellate Tribunal will be set up to examine cases and hear appeals against confiscating
This document provides answers to frequently asked questions about property sales in Abu Dhabi. It states that UAE nationals and GCC nationals can own land anywhere in Abu Dhabi and in designated investment areas, while other nationalities can only invest in investment areas. It defines investment areas and musatahas (ground development leases). Common buyer obligations include following use rules and paying service charges. Inherited properties transfer to heirs. Registration fees are 2% of property value or 1% of annual rent. There are no property or rental taxes, and mortgages are available from banks and financial companies. Lawyers are not strictly needed but recommended. Property purchase does not guarantee a residence visa.
The document summarizes key concepts in Philippine real estate law, including:
- Ownership rights include the right to possess, use, enjoy fruits, dispose of, and recover property. Limitations include those imposed by law, contract, taxation, and eminent domain.
- Land ownership extends to the subsurface and airspace. Hidden treasures found on one's land belong to the land owner, with exceptions if found on another's land.
- Ownership rights include rights of accession to property's produce and improvements. Generally, only Filipino citizens and corporations may acquire land, with some exceptions.
The document is a lease agreement between a lessor and lessee for the leasing of a bank guarantee (BG). Key details:
- The lessor agrees to lease a BG of at least $5 million USD/Euro to the lessee.
- The lease price is 6% of the face value of the BG plus 2% commission for the lessor and lessee agents.
- Payment will be made via wire transfer. The BG will be delivered via SWIFT message to the lessee's bank within 3 days of payment confirmation.
- The agreement outlines the roles, responsibilities, and procedures between the lessor and lessee regarding the lease and delivery of the
The document discusses retention of title, or reservation of ownership, under Vietnam law. Retention of title is first mentioned in Vietnam's 1995 Civil Code but is regulated across several laws. Ownership is usually transferred when the buyer receives the property, or registration is complete. However, parties can negotiate the transfer time by agreement. For deferred or installment payments, the seller reserves ownership until full payment unless otherwise agreed. The parties can also agree to a trial use period where the seller retains ownership while the buyer uses the property. In conclusion, Vietnam law allows ownership reservation in cases of party agreement, the type of agreement, or as prescribed by law.
This document provides an overview of chapter 17 exhibits related to federal estate, gift, and generation-skipping transfer taxes. It lists 27 exhibits that cover topics such as the formula for computing estate tax liability, definitions of key terms, different forms of property ownership like tenancy by the entirety and joint tenancy, life insurance proceeds, annuities, gifts, deductions from the gross estate, and generation-skipping transfers. The exhibits provide examples and explanations of these various concepts.
What Every Renter in Massachusetts Should Know in This Foreclosure CrisisDawn Hicks
This document summarizes tenants' rights during the foreclosure crisis in Massachusetts for renters living in foreclosed properties. It explains that tenants are protected by state laws and do not need to immediately vacate when a property is foreclosed. Specifically, it notes that tenants with leases become month-to-month tenants and are entitled to 30 days notice before eviction, while Section 8 tenants can remain until their lease ends. It provides contact information for legal assistance and details two pieces of proposed federal legislation that would provide tenants with formal notification and more time before an eviction.
CGT rollover relief on marriage breakdown | Family Business Accountants | Wes...Craig Seddon
The effect of the roll-over relief is that the normal CGT rules don't apply in relation to the disposal, so there are no CGT consequences to the transferor.
The transferee acquires the asset with the same CGT nature which it had in the hands of the transferor.
https://www.westcourt.com.au
Arizona Divorce, Modification, and EnforcementBillie Tarascio
The document provides an overview of divorce law in Arizona, covering topics like property division, spousal maintenance, child custody and support. It explains that in a divorce, courts must identify and characterize all assets and debts as community or separate, then equitably divide the property. Spousal maintenance determinations involve two steps - establishing qualification based on factors like need, then considering amounts and duration based on finances and standard of living. Child custody decisions are made in the best interests of the children based on factors evaluating each parent and their relationship with the child.
final notes civil code bar q's (AutoRecovered).pdfChrisselTabasa4
The document discusses various topics in civil law, including:
1. The elements required to claim damages from a quasi-delict or negligent act.
2. The process for obtaining a judicial declaration of presumptive death to allow remarriage.
3. Parental authority over illegitimate children.
4. Recognition of foreign divorce decrees in the Philippines.
5. Various rules regarding donations, property regimes, ownership rights, and other civil law matters.
Jean is considering marrying her boyfriend Joe but is concerned because Joe owes back taxes. The document provides the following advice:
1) Jean should not marry Joe until his tax problems are resolved, otherwise his tax debt could become her responsibility.
2) Filing jointly could make Jean liable for Joe's back taxes, so she should consider filing separately or getting a prenuptial agreement to protect her assets.
3) If they file jointly and the IRS keeps their refund for Joe's back taxes, Jean can file an injured spouse form to try to get her portion of the refund back.
Civil Resolution Tribunal | Vancouver | British ColumbiaRailtown Law
The document discusses the creation of a new Civil Resolution Tribunal in British Columbia that will handle disputes between strata owners and strata corporations. Currently, such disputes can only be heard through the expensive BC Supreme Court process. The Tribunal aims to provide affordable resolution options like online negotiations, mediation, and adjudication. This should deter unfair treatment of owners by strata councils that often face no consequences for misapplying laws and bylaws. Individuals can access the Tribunal's services without lawyers starting in early 2014. Strata councils may face more complaints through this external process and should review their practices in preparation.
FCS 3450 HOMEWORK #41.Thomas Franklin arrived at the following t.docxmydrynan
FCS 3450 HOMEWORK #4
1.
Thomas Franklin arrived at the following tax information:
Gross salary, $46,660
Interest earnings, $225
Dividend income, $80
One personal exemption, $3,400
Itemized deductions, $7,820
Adjustments to income, $1,150
What amount would Thomas report as taxable income?
2.
If Lola Harper had the following itemized deductions, should she use Schedule A or the standard deduction? The standard deduction for her tax situation is $5,450.
Donations to church and other charities, $1,980
Medical and dental expenses that exceed 7.5 percent of adjusted gross income, $430
State income tax, $690
Job-related expenses that exceed 2 percent of adjusted gross income, $1,610
3.
What would be the average tax rate for a person who paid taxes of $4,864.14 on a taxable income of $39,870?
4.
Based on the following data, would Ann and Carl Wilton receive a refund or owe additional taxes?
Adjusted gross income, $46,186
Itemized deductions, $11,420
Child care tax credit, $80
Federal income tax withheld, $4,784
Amount for personal exemptions, $6,800
Average tax rate on taxable income, 15%
5. Would you prefer a fully taxable investment earning 10.7 percent or a tax-exempt investment earning 8.1 percent? Why? (Assume a 28 percent tax rate.)
6. On December 30, you decide to make a $1,000 charitable donation. If you are in a 28 percent tax bracket, how much would you save in taxes for the current year? If that tax savings was deposited in a savings account for the next five years at 6 percent, what would be the future value of that account?
1
Assignment 2: JPMorgan Chase
Strayer University
LEG 100
Discuss how administrative agencies like the Securities and Exchange Commission (SEC) or the Commodities Futures Trading Commission (CFTC) take action in order to be effective in preventing high-risk gambles in securities / banking, a foundation of the economy.
On January 11, 2012, the Commodity Futures Trading Commission (CFTC) voted 3-2 to propose regulations to implement Section 619 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act), commonly referred to as the “Volcker Rule.” The proposal specifically prohibits a bank or institution that owns a bank from engaging in proprietary trading that is not at the behest of its clients, and from owning or investing in a hedge fund or private equity fund, and also limits the liabilities that the largest banks can hold .Under discussion is the possibility of restrictions on the way market making activities are compensated; traders would be paid on the basis of the spread of the transactions rather than any profit that the trader made for the client.
Determine the elements of a valid contract, and discuss how consumers and banks each have a duty of good faith and fair ...
Chartered Secretary - The Black Money Act - is It a PanaceaSudipto Banerjee
The article analyzes India's Black Money Act, which came into effect on July 1, 2015. Some key points:
- The Act taxes undisclosed foreign assets and income of resident Indian citizens at 30% and also imposes severe criminal penalties for tax evasion.
- It allows for a one-time compliance window until December 2015 for declaring foreign assets with a penalty of paying the tax due plus a 100% penalty.
- Significantly, the Act defines willful attempt to evade tax as a "predicate offense" under India's anti-money laundering law, allowing tax authorities and the Enforcement Directorate to investigate cases jointly.
- This is aimed at enabling India to seek more cooperation from
SB 179 aims to reform landlord/tenant regulations in Wisconsin to protect the rights of both landlords and tenants. It provides several improvements, such as limiting a tenant's financial responsibility to damages stated in their original agreement. It also requires landlords to disclose any written housing code violation notices to prospective tenants. Additionally, the bill provides new protections for domestic violence victims living with perpetrators of crimes on rental properties.
Legal and tax implications when purchasing real estate in Spain, EnglishDe Micco & Friends Group
Here you will get all important information when you sell or buy real estates in Spain and Mallorca,
It is generally recommended that buyers of real estate in Spain instruct a qualified lawyer to represent them and hire a financial advisor knowledgeable in local and international taxes and dues to take care of the tax aspects. Spain does meanwhile provide a relatively high amount of legal protection for real estate purchases, but there are still cases in which the buyer has to battle enormous problems or unexpected expenses after the acquisition because certain processes were not adhered to, documents weren't checked or contracts were drafted which include substantial disadvantages for the buyer. 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.
Through a will, one can achieve significant tax benefits such as establishing a separate tax filing for a Hindu undivided family, making tax-free bequests to minor children or grandchildren to avoid income clubbing, transferring assets to a spouse or daughter-in-law without tax implications, and creating a charitable trust. A will allows one to create a new Hindu undivided family as a separate tax entity, make bequests that result in separate funds for minor beneficiaries avoiding clubbed income, and transfer property to a spouse or daughter-in-law after death when there is no question of income clubbing.
The document provides information about business structures, finding company information, credit checks, contracting, litigation processes, and courts in the United Arab Emirates. The most common business structure is a limited liability company. Company information can be found on chamber of commerce websites. Credit checks and judgments against businesses are available through credit reporting agencies. Litigation requires original documentation and translation to Arabic. Alternative dispute resolution includes arbitration and mediation, with some claims requiring attempted settlement first. Court proceedings involve filing claims through the court system consisting of courts of first instance, appeal, and cassation.
Types of Mortgages in Housing loan & the rights of the lenderPratistha Mishra
Types of Mortgages that are provided by the lenders in Housing Loan & what the rights of the Mortgagor & Mortgagee along with it what are the essentials of each type of mortgage.
Similar to Step conference eng 1 7-2015 final (19)
2. Artzi,Hiba,Elmekiesse,Cohen
www.ahec-tax.co.il
1. An endowment to a trustee in a trust is not classified as a sale as
long as the settlor and the beneficiary are the same, and the
principle of tax continuity is maintained - Section 3 of the real estate
taxation law (the “Law”).
2. There is no correlation between the definition of a trust in the Income
Tax Ordinance (the “Ordinance”) and between the Law.
3. Sections 74 and 73(F) of the Law set the rules regarding the
announcements with respect to a trust.
This means that the transfer of real estate from the existing owner to a
trust in favor of a beneficiary, who is not the owner, is a tax event under
the Law.
Real Estate Taxation Law
2
3. Artzi,Hiba,Elmekiesse,Cohen
www.ahec-tax.co.il
Endowment to a trustee, guardian, etc.
3 Endowment of right to land or a right in an association to a trustee,
guardian, liquidator or receiver pursuant to the Bankruptcy Ordinance,
1936, the Companies Ordinance, the Cooperative Societies
Ordinance, the Trading with the Enemy Ordinance, 1939, the
Absentees Properties Law, 1950, or the Germans Properties Law,
1950, or to a company as defined by the Assets of the Holocaust
Victims Law (Restitution to Heirs and Endowment for Purposes of
Assistance and Commemoration), 2006– is not “sale of a right to land”
or an “act in an association” for the purpose of this law; and in the sale
of a right to land or an act in an association by a person to whom it
has been endowed as set forth, the calculation of the tax, including
pursuant to Section 7A, will be as though the right had been sold or
the act performed by a person from whom it was endowed.
Real Estate Taxation Law –
quotation of relevant sections
3
4. Artzi,Hiba,Elmekiesse,Cohen
www.ahec-tax.co.il
Announcement of a trust:
74. Any person who purchases in his own name for a given person a
right to land or a right to a property association, will inform the
Director, in the form prescribed by the Director has, within thirty
days of the day of purchase, that he has purchased the right in his
own name for another person, and once announcing this he will be
considered as a trustee for the purpose of Section 69.
Real Estate Taxation Law –
quotation of relevant sections
4
5. Artzi,Hiba,Elmekiesse,Cohen
www.ahec-tax.co.il
Declarations
73. (F) Any person who possesses in his own name for an unidentified
another person a right to land or a right to a property association,
and any person who possesses a power of attorney to register a
right to land to the name of the buyer or to his order, will inform the
Director, notwithstanding the provisions in any law, of the sale of the
right to the land or the action in the property association resulting
from which he will possess that right or the power of attorney for
another person, within thirty days of the date of him being given a
notice of that sale or action, unless that sale or action is not taxable
pursuant to this law; the foregoing does not diminish from the duty
under Subsection (A).
Real Estate Taxation Law –
quotation of relevant sections
5
6. Artzi,Hiba,Elmekiesse,Cohen
www.ahec-tax.co.il
Example:
Parents requesting to transfer 2 apartments to their 2 daughters who
have reached the age of 20 and are unmarried.
The parents request that the apartments will not to be transferred
directly to the daughters but to a trust.
In addition, the needs of each of the sisters in the future are unclear.
Apartments that have been received from the parents as a gift can’t
be exchanged between the sisters under an exemption from
betterment tax and from purchase tax.
According to the trust’s deed, the apartments may be attributed to
each of the daughters in equal shares, or each apartment may be
attributed to a specific daughter. The apartments will be registered
under the trustee’s name in the land registrar office
Real Estate Taxation Law
6
7. Artzi,Hiba,Elmekiesse,Cohen
www.ahec-tax.co.il
The solution:
Establishing a trust – transferring the apartments to a trust will be considered
as a gift from the parents to the daughters, and therefore:
1. It is exempt from betterment tax – Section 62 of the Law will apply.
2. Purchase tax will be paid – 1/3 of the ordinary purchase tax.
3. The trustee will have the full discretion to decide, in accordance with the
needs of the daughters, which apartment will be attributed to each of the
daughters for their usage.
4. The apartments’ occupancy by the daughters will not be subjected to rent
charges since, for betterment tax purposes, the daughters are considered
as the owners of the apartments.
5. Provisions may be determined – how the apartments will be sold and the
proceeds be distributed between the daughters or the exchange of the
apartments between the daughters (exchange in the usage, otherwise
differences in the registration of the apartments in the land registrar office
will be subject to betterment tax and purchase tax).
Real Estate Taxation Law
7
8. Artzi,Hiba,Elmekiesse,Cohen
www.ahec-tax.co.il
The solution - continued:
Upon the sale of the apartments to third party, the provisions of tax continuity
will apply, even though 1/3 of the purchase tax was paid by the daughters.
The parents’ ownership period of the apartments will be considered as
ownership of the daughters upon the sale of the apartments.
In such a case, the transfer of the apartments to the trust may allow to
withstand the estate tax and gift tax, if such laws will be legislated.
Real Estate Taxation Law
8
9. Artzi,Hiba,Elmekiesse,Cohen
www.ahec-tax.co.il
Section 125C(D)(3) of the Ordinance states that a loan granted by an
individual who is a substantial shareholder (10% or more) in a company, as
defined in Section 88 of the Ordinance, will be subject to the marginal tax
applying to such individual (up to 48% today), instead of a tax rate of 25%
that apply to interest income, or a tax rate of 15% applying to interest income
originating from a loan that is not index linked (an additional 2% surtax may
be applicable in all cases).
The provision above also applies to the relative of an individual who is a
substantial shareholder in the company, even if such relative holds less than
10% in the company or holds no shares at all, in view of the definition of
“substantial shareholder” to which Section 125C of the Ordinance refers.
Thus, if the brother of the individual (hereinafter – “the Brother”) grants a loan
to a company, he will be taxed with the marginal tax rate because he too (the
Brother) is considered as a substantial shareholder.
Restricted tax rates for interest on loan
that is granted within a trust structure
9
10. Artzi,Hiba,Elmekiesse,Cohen
www.ahec-tax.co.il
Restricted tax rates for interest on loan
that is granted within a trust structure
10
Company
Individual
100%
Brother
Loan
granting
Interest with respect to both of the loans is subject to the marginal tax rate
Loan
granting
11. Artzi,Hiba,Elmekiesse,Cohen
www.ahec-tax.co.il
Restricted tax rates for interest on loan
that is granted within a trust structure
11
Company
Individual -
Settlor and
beneficiary
100%
Brother
Loan
granting
Interest with respect to both of the loans is subject to the marginal tax rate
Loan
granting
Trust
100%
13. Artzi,Hiba,Elmekiesse,Cohen
www.ahec-tax.co.il
Instead of the Brother granting a loan directly to a company that is held by the
individual (who is his relative), the Brother’s existing trust, in which he and his
family are the beneficiaries, will grant a loan to the company.
The trustee in the Brother’s trust is considered to be a relative of the Brother, but
not a relative of the individual.
One can raise the argument that since the Brother is a relative of the individual,
and the trustee in the Brother's trust is a relative of the Brother, than the trustee
in the trust is also a relative of the individual.
This arguments has no standing in the wording of the law, and this is not the
purpose of the law (otherwise all the people of Israel are brothers) and secondly,
in a recent published taxation decision (# 4938/14) discussing the issue of family
relation in relatives’ trusts, the Israeli Tax Authority (“ITA”) stated that even
though an individual is a relative to his brother, and the brother is a relative to his
spouse, the spouse is not a relative to the individual. With this decision the
ITA adopted an approach that rules out this argument and supports the
interpretation above.
Restricted tax rates for interest on loan
that is granted within a trust structure
13
14. Artzi,Hiba,Elmekiesse,Cohen
www.ahec-tax.co.il
Therefore, in the case described above, interest income derived from a
loan granted by the trustee of a trust that the Brother has established,
in our view, is subject to tax at a rate of 25% or 15% rate, as the case
may be, and not at the marginal tax rate that would apply in the case of
a direct loan (an additional 2% surtax may be applicable).
Restricted tax rates for interest on loan
that is granted within a trust structure
14
15. Artzi,Hiba,Elmekiesse,Cohen
www.ahec-tax.co.il
The use of Section 75G(G) – distributions
to beneficiaries
15
Father –
Foreign Settlor
Son –
Israeli Beneficiary
Daughter - new Immigrant /
Long term or regular returning resident at
2012 (“qualified individual”)
Beneficiary
Trust
16. Artzi,Hiba,Elmekiesse,Cohen
www.ahec-tax.co.il
Assumptions
1. The trust income derives from abroad.
2. The trust is classified as a relative trust.
Taxation:
1. Trust’s income which is attributed to the Israeli beneficiary or distribute to
him will be taxed according to the applicable provisions of the Ordinance
(25% or 30% according the selected track).
2. Trust’s income which is attributed to a qualified individual or distribute to
him will be exempt from tax according to the benefits grated by law
(within the benefits period).
3. According to the wording of the Ordinance, section 75G(G) does not
aplly to relative trust.
The use of Section 75G(G) –
distributions to beneficiaries
16
17. Artzi,Hiba,Elmekiesse,Cohen
www.ahec-tax.co.il
The use of Section 75G(G) – distributions
to beneficiaries
17
Father - Settlor
(immigrated to Israel during 2015)
Son –
Israeli Beneficiary
Trust
Daughter – Qualified
individual at 2012
18. Artzi,Hiba,Elmekiesse,Cohen
www.ahec-tax.co.il
Consequence – the trust is classified as an Israeli resident trust, from the
date the settlor became an Israeli resident.
Taxation
1. The trust is taxed according to section 75G, which sets the provisions
applying to Israeli residents trust, including possibility to attribute the
revenues to beneficiaries who are Israeli residents, up to the amount
distributed to them within 6 months from the end of the tax year.
2. The trustee is not eligible to benefits granted to the settlor who is an
qualified individual, because one of the beneficiaries in the trust is not
qualified individual (i.e. the son who is just a regular Israeli resident).
3. Only if all the beneficiaries (the daughter and the son) and the settlor
(the father) are qualified individuals, the trust’s income will be exempt
from tax according to the benefits grated to a qualified individual.
The use of Section 75G(G) –
distributions to beneficiaries
18
19. Artzi,Hiba,Elmekiesse,Cohen
www.ahec-tax.co.il
Solution
1. Since section 75G applies to the trust’s income, the trustee and the
beneficiaries may elect, each year, to be taxed according to section
75G(G) to the Ordinance.
2. Section 75G(G) sets the possibility to attribute the revenues to
beneficiaries who are Israeli residents, up to the amount distributed to
them within 6 months from the end of the tax year.
3. Thus, under such election, and provided that the other conditions in
section are satisfied, all qualified distributions to a beneficiary who is a
qualified individual (i.e. the daughter) are subject to the benefits granted to
qualified individual.
The use of Section 75G(G) –
distributions to beneficiaries
19
20. Artzi,Hiba,Elmekiesse,Cohen
www.ahec-tax.co.il
The formation of such a mechanism will also assist in the case when
having in an Israeli residents trust beneficiaries whose remaining
benefit period is greater. In other words, distributions will be made
first to the beneficiaries whose benefit period is about to end and only
in the following years to those who are still entitled to benefits.
Generally speaking, the section helps to average out and to maximize
the tax benefits of the family fortune that is managed by a trust that
fulfills the definition in the section. The trustee may also be able to
distribute certain revenues to certain beneficiaries with consideration
of the tax rates applying to them, exemptions to which they are
entitled and offsettable losses that have been accumulated for them.
The use of Section 75G(G) –
distributions to beneficiaries
20