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Timms Announces UK Tax Treaty Priorities
27 hours ago
UK Treasury minister, Stephen Timms, has announced details of the UK’s treaty negotiating priorities for the year to March 31, 2010, which includes plans to progress double taxation and information exchange agreements with about 20 onshore and offshore jurisdictions. |
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Applicability Of Italian CFC Rules Extended
25 hours ago
The official publication of the decree containing the Italian government’s
latest economic package of measures has confirmed the extension of anti-avoidance
CFC (controlled foreign company) rules beyond the confines of tax havens. |
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Business Welcomes US Review Of Andean Trade Preferences
27 hours ago
Business and trade organizations representing some of the largest US multinationals have welcomed the Obama administration’s review of country eligibility for trade preferences under the Andean Trade Preference Act. |
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Gibraltar Budget Reshapes Fiscal Outlook For Corporates
21 hours ago
Gibraltar’s Chief Minister Peter Caruana delivered his 2009/2010 budget
speech on June 26, outlining plans for the reform of the jurisdiction’s
tax system to apply a 10% corporate tax rate, and other incentives to allow
it to compete with the world’s leading international finance centres. |
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April Deadline For GST Introduction In India Is Increasingly Unlikely
25 hours ago
Amending the Constitution to provide wider taxation powers to both the states and the Centre is proving one of a number of obstacles in implementing the Goods and Services Tax (GST). Amid rumblings in the states that the uniform tax is diametrically opposed to the federal principles of the Constitution, any amendment to the Constitution would require a two-third majority in both Houses of Parliament, with a quorum of not less than 50%. |
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| User
Comments | Views | Q & A
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| Partnership Tax Deferral U.S. and Foreign Based Income |
| My licensee client has purchased a U.S. patent invented by NASA scientist (2007, 24 claims) for the marketing and manufacture of breakthrough state of the art radiation detection technology (lab report, field test, Scientific Evaluation) and has entered into a JV with certified U.S. defense contractor. Worldwide market has been established by INSEAD at $25 billion over next 10 years. Amortization of license cost will provide tax deferred partnership losses at 5:1, with economic substance and substantial expectation of profits. What EU countries other than U.S. and Italy allow partnership tax losses against other income? (Seems Germany, France, Belgium and Sweden do). We also need a private placement agent in EU. Michael |
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| REPLY:
I can answer you for France which i know well: Yes, you can deduct partnership tax losses against other income, but not every income. It must be the "same sort" of income (For example, gains from another partnership are ok, but real estate income wouldn't !) Wouldn't it be better to have a company in a country which allow you to carry forward losses indefinitely (until you finally do profits) ? And even better, with a low corporate tax ? lowtax@live.fr |
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REPLY:
You can deduct partnership tax losses against other income in Bulgaria.
If my best guess about what you are trying to achieve is correct, there may be a much more efficient solution to the problem. A registered finacial institution (not to be confused with banks or licensed financial brokers), allowed to trade everything, and mark-to-market just any asset, could give you all the flexibility you need. The registration requirements are as low as a limbo bar, and the registration costs are around EUR 5 000.
A private placement agent is readily available, but again, it may be wise to consider some more creative options.
Cato, www.marketvectors.bg |
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| REPLY:
In the U.S. partners (or LLC members) may use a portion of partnership debt to increase capital account tax basis, thus to take a greater loss pass through than their contributed capital, caused by amortization of an intangible asset. In this case the license cost is so substantial that the only feasible way for licensee to purchase was promissory note, making a share of that debt available to members to increase tax basis. This is a legitimate (not abusive) tax deferral, much like films or forestry deferrals (also referred to as shelters), where the original tax breaks are so substantial that the investment becomes palatable to "carriage trade" investors in this horrible economy for tax savings. Conversely, equity capital is most difficult today even for the most palatable business opportunity in state of the art technology. Michael |
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REPLY:
Unfortunately, under the current market conditions, tax breaks, no matter how generous, may not be enough of an incentive. In early June, the private equity guys had an investable $830 billion worldwide, and most of the money outside the US was in Japan and the Middle East.
I would imagine that Mrs. Vatanabe would be of greater assistance than continental Europe.
Good luck Cato |
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| Offshore Company |
Hi,
If anyone could help - it would be much appreciated.
I am starting a company that is basically an affiliate to an online lottery ticketing service - they purchase tickets for international lotteries for non-residents around the world. All my company/website would be doing is pointing clients towards the other company that I am affiliated with. Therefore, I would not be involved in any of the transactions or services. I am based in South Africa but would like to set up a company in Mauritius. I've looked into a possible GBC2 company. Is this a viable option and what would the tax implications be? As it is an online service that would be used globally. This is also by no means a big budget company as yet so would also be looking into the most cost effective options.
Thanking you in anticipation. Happy |
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REPLY:
hi please send me an email on neermal.poonie@yahoo.co.uk, will advise you accordingly.
Thanks |
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| B.V. Company in the Netherlands |
We are looking for a flexible and cost effective approach to our tax planning where we propose to open a wholly owned Sub in the Netherlands. This sub would own international rights to a product we sell. Eventually, the goal would be to reduce our taxable income by charging a royalty to a second, wholly owned sales sub in our target market, the UK. For the initial phase, sales in the UK would be through the Netherlands Company, but as they grew, the UK office would be opened and we would charge that office a royalty on sales, which would not be taxable in the Netherlands.
Is this viable? If so, who can you recommend to set up our first sub in the Netherlands and for what estimated cost? Thanks
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| Suitable company and banking solution |
I'm starting an online business that is essentially a booking service for restaurants around the world. Diners will be submitting payment through our website for dinner and we will forward payment from the dinner to the restaurant.
It would be best for the diners if they were able to submit payment in the same currency as that used in the restaurant.
Obviously I will need an on-line debit/credit card payment processing system. What sort of banking facility is available that would support a large number of different currency transactions both from customers and to our restaurants?
Or should i be looking at incorporating something like hoopay as an intermediary between customers and our company account? p.s. |
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| REPLY:
Please contact us at info@freemontgroup.com Freemont Group |
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REPLY:
Hi, I would suggest that you need a multi-currency banking facility allied to a third party multi-currency merchant facility. This will allow your clients to order via your web site and pay funds in their or the restaurants local currency and for this be received by you in that same currency, rather than it having been exchanged already, which may cause you some problems and potentially cost you money in exchange losses. You may then pay out from your multi-currency account in any currency to the restaurant and retain your profit element in whichever currency is most favourable for you. You may wish to do this via an offshore corporate structure with offshore banking or simply arrange a multi-currency account for your existing company. Either way we can assist you.
Please feel free to contact us on enquiries@turnerlittle.com or via our web site at www.turnerlittle.com
Advisor - Turner Little Limited |
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| Denmark tax |
I am a British national living in Denmark. The marginal tax rate in Denmark is 63%!!!!!, so by now I am pretty tired of that.
Am considering starting my own company (investment management/mutual fund). Where is the most tax efficient place to live / set up the company? Philip |
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REPLY:
Try Bulgaria.
How about 10% corporate income tax and dividends taxed at 5%? Both are anyway mostly irrelevant given the 10% flat-rate personal income tax and the generous tax breaks from all three. The EU membership is a bonus. |
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| REPLY:
Try Cyprus - English speaking, sunny, relaxed and... low tax (10% CT). Freemont Group |
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