The new revenue procedure issued by the Internal Revenue Service on requests for competent authority assistance is good news for taxpayers. It should assist taxpayers by providing more detailed information on when it is appropriate to apply for assistance, and how....
In the wake of the changes to the way that foreign pensions (including 401-k’s and IRAs) are taxed in New Zealand the Inland Revenue Department (IRD) has recently refined its position with respect to foreign tax credit availability. The way that pension income...
Late in 2014, we commented on the IRD’s position on the availability of foreign tax credits for New Zealand tax residents, with respect to United States-sourced pensions. The current situation gives rise to double taxation with respect to pension income arising...
Article 19 of the income tax treaty in force between New Zealand and the United States sets out which country gets taxing rights to pensions from government service. Not to be confused with social security benefits, which are only taxable in the source country (New...
If you are thinking about expatriating, beware of taxation under Section 877 and 877A of the Internal Revenue Code – Expatriation to avoid tax, and tax responsibilities of expatriation. Covered expatriates are subject to specific taxing mechanisms under...
