International taxation - A new procedure for voluntary disclosure – probably the last chance
On and off and in various incarnations since 2005, taxpayers have been able to come forward to the Israel Tax Authority to settle and disclose data on hidden income and assets not previously reported as required by law.
International taxation - A last-minute declaration of the Tax Authority's position on taxation of "virtual currencies"
The Income Tax Ordinance stipulates the taxpayers obligations to report in their tax return whether they have taken a "reportable tax position". The Tax Authority has added a position entitled "taxation of virtual currencies" to that list. The Tax Authority indicates there that
International taxation - Sale by a new immigrant or returning resident of shares in a foreign company, part of whose value is derived from Israeli assets
As part of the list of reportable tax positions published by the Tax Authority, a position has been added on the sale by an individual who immigrated to Israel either for the first time or after a period of 10 years or more (such a "beneficiary individual" has a 10-year exemption from
International taxation - Business investments – insight from taxation decisions on the subject of permanent establishment for foreign investors
Many entrepreneurs wish to direct their available capital to investment in Israeli companies in a variety of areas, in particular – the Israeli high-tech sector, known to be one of the central growth engines of the economy. Government
Voluntary disclosure and trusts - Probably the last chance - new voluntary disclosure procedure
As is well known, since 2005, alternately and in different variations, citizens had the option existed for submitting a request to the Israel Tax Authority, to arrange and disclose data on income and assets that had previously been concealed, rather than disclosed as required under the law.
Voluntary disclosure and trusts - Cancelling the requirement for deduction at source for certain transfers of funds abroad
Many Israelis encounter considerable difficulty when transferring funds abroad in order to purchase assets, shares in foreign corporations, etc. This is because the Income Tax Ordinance determines compulsory deduction of tax at source for an Israeli paying a foreign resident, at the companies tax rate (currently 24%); or alternately 25% in the case of a foreign individual resident.
Voluntary disclosure and trusts - Should foreign companies profiting from sale of real estate and shares be counted as CFCs?
In a recently published ruling on the matter of Rosebud, the question of classification of income from sale of shares and real estate was discussed with regard to defining a CFC – Controlled Foreign Corporation. Summary of the main facts of the case:
The Dutch Ministry of Finance has published clarification with regard to classification for tax purposes of “inferior loans”, i.e.: dead loans or long term loans (over 50 years): with regard to these, the lender is entitled partial or entire payment only in the event of