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Last year, the UK and Luxembourg signed a new double tax treaty, which officially came into force on 22 November 2023.
This development brings significant changes, particularly in how capital gains are treated.
For Luxembourg-based investors in UK real estate, the clock is ticking to adapt to these changes.
Previously, Luxembourg residents could sell stakes in UK property-rich entities without worrying about the UK’s tax net.
But, the updated treaty has flipped that particular script.
Now, if you’re a Luxembourg resident and you dispose of shares (or interests in partnerships or trusts) that derive more than half of their value from UK real estate, the UK will have a say in your tax bill.
This change primarily affects entities where at least 75% of their value comes from UK real estate, as UK tax laws have targeted such gains since 2019.
So, if your investment structure falls into this category, it’s time to pay attention.
Mark your calendars!
The treaty’s provisions will be implemented as follows:
This isn’t just a minor lick of paint.
The lack of ‘grandfathering’ for existing structures means that Luxembourg investors in UK real estate could face significant tax implications.
It’s a key time to review your investment structures and consider strategies to navigate these changes.
One trend is a shift to using Real Estate Investment Trust (REIT) status prior to 1 April 2024.
This move aims to capitaliae on the current rules for conversion and then leverage the REIT regime moving forward.
Change is often challenging, but it also brings opportunities for adaptation and growth.
If you’re a Luxembourg investor in UK real estate, now is the time to review your portfolio and strategies. As always, professional advice tailored to your specific circumstances is key in making the most of these changes.
If you have any queries about the New UK-Luxembourg Tax Treaty, or are a property investor in the UK and looking at options, then please get in touch.
On 16 October 2023, the Council of Ministers preliminarily approved a legislative decree proposing significant reforms to international taxation in Italy.
This decree is currently undergoing review by relevant parliamentary committees before it officially becomes law.
An interesting proposal is a relief for the so-called ‘reshoring’ of economic activities.
Let’s look at this in some more detail.
Expected to come into force after final approval of the legislative decree (anticipated by December 31, 2023), the ‘reshoring’ provisions aim to rejuvenate Italy’s economic landscape.
However, their actual enactment hinges on authorization from the European Commission.
Article 6 of the draft legislative decree outlines a specialized tax incentive designed to incentivize the transfer of ‘economic activities’ to Italy.
Unlike similar measures in other nations, Italy’s decree extends beyond specific sectors, aiming to encompass ‘economic activities’ regardless of industry.
Under the proposed measure, income derived from business activities transferred from non-EU or non-EEA countries to Italy will enjoy a 50% exemption from income tax and IRAP (Regional Production Tax) for a designated period:
The relief spans the tax period during the transfer and the following five tax periods. However, ‘economic activities’ already conducted in Italy within the preceding 24 months are excluded from eligibility. Interpretive Challenges and Scope The decree poses several questions for stakeholders, primarily concerning its application scope.
The term ‘economic activities’ casts a wide net, referencing income from business activities conducted in non-EU/EEA countries and relocated to Italy.
This suggests potential application scenarios, including the relocation of non-EU/EEA companies’ registered offices to Italy.
Though the draft decree doesn’t explicitly mention the combined application of ‘reshoring’ relief and tax basis adjustment provisions, such as Article 166-bis of the Consolidated Income Tax Law (TUIR), experts opine that these could complement each other.
This combination might lead to higher depreciation or lower capital gains, further reducing the taxable base.
Determining the application of ‘reshoring’ relief, along with compliance with other provisions like ‘Pillar 2’ and ‘Qualifying Domestic Minimum Top-Up Taxes,’ poses intricate challenges.
The definition of ‘economic activity’ under European Union law highlights the complexity of identifying eligible activities.
Moreover, entities already established in Italy undergoing functional changes might potentially qualify for ‘reshoring’ benefits.
This includes transformations within the value chain, such as a distributor evolving into a manufacturing entity.
To benefit from the incentive, taxpayers must maintain meticulous accounting records to verify income determination and eligible production values.
The legislation stipulates forfeiture conditions, triggering the recovery of unpaid taxes in case of activity transfer out of Italy within specific periods following ‘reshoring.’
Italy’s proposed tax incentive for ‘reshoring’ economic activities presents opportunities and complexities for businesses.
The legislation’s interpretation and application nuances warrant thorough understanding, and compliance measures are crucial to harness the benefits while navigating the regulatory landscape effectively.
If you have any queries around Italy and reshoring of economic activities, or Italian tax matters in general then please get in touch.
The content of this article is provided for educational and information purposes only. It is not intended, and should not be construed, as tax or legal advice. We recommend you seek formal tax and legal advice before taking, or refraining from, any action based on the contents of this article.
The Portuguese Prime Minister announced an intention to terminate the “Non-Habitual Resident” taxation regime (‘NHR Regime’).
This has been an attractive and popular tax regime that provided tax benefits to non-residents moving to Portugal.
On 10 October 2023, the Draft State Budget Law proposed the end of the NHR Regime from 1 January 2024.
This means that individuals acquiring tax residency in Portugal or holding a Portuguese residence permit until 31 December 2023, can still apply for the NHR Program.
The final draft law is expected to be available by the end of November 2023.
The practical issues are perhaps, refreshingly simple.
Those individuals wishing to benefit from the NHR Regime must establish tax residency in Portugal before December 31st, 2023, and submit the NHR application promptly.
As such, there is a feel of an ‘Everything Must Go’ style fiscal sale in the offing.
Under the 2024 Draft State Budget Law, individuals relocating to Portugal between 1 January 2024, and 31 December 2026, who haven’t resided in Portugal in the previous 5 years, are eligible for a 50% deduction on taxable income, up to a maximum of €250,000 for 5 consecutive years.
Standard progressive tax rates apply to the remaining taxable income, and foreign-source income may be taxable in Portugal. Contractors and freelancers may have additional deductions during the first and second years.
In addition, a new taxation regime, available for 10 years, will apply to individuals who have not resided in Portugal for the past 5 years.
It’s limited to university professionals, scientific research, income from companies with contractual tax benefits for productive investment projects, and income from companies under the R&D tax incentives system (SIFIDE) paid to individuals with a PhD.
Under this regime, foreign-source income (except pensions) will be exempt, and a flat 20% tax rate will apply to employment and self-employment income. Those benefiting from the NHR or the 50% exclusion regime are not eligible.
The Portuguese Personal Income Tax Code offers an attractive regime for income generated through life insurance or pension funds.
Regular investment income is taxed at a flat rate of 28%, with portions of income from life insurance or pension funds being exempt under certain conditions.
Other efficient taxation arrangements can be considered on a case-by-case basis.
Please note that this information is subject to change based on the final draft law.
Of course, there are other jurisdictions around the world happy to accommodate mobile, wealthy, and tax savvy individuals.
Cyprus and Italy both offer attractive ‘non-dom’ regimes for individuals.
Jurisdictions like the UAE continue to offer welcoming low or nil personal tax rates.
If you have any queries about the Non-Habitual Residence (NHR) regime, Portuguese tax, or tax matters in general, then please get in touch.
The wheels of international tax reform continue to turn as Canada takes significant strides to implement the OECD’s Pillar Two global minimum tax (GMT) recommendations.
On August 4, 2023, the Department of Finance unveiled draft legislation outlining the implementation of two pivotal elements of Pillar Two: the income inclusion rule (IIR) and a qualified domestic minimum top-up tax (QDMTT).
The aim is to align Canada’s tax landscape with the evolving international consensus on curbing tax base erosion and profit shifting.
Let’s have a look at the key aspects of this draft legislation, along with insights into the broader implications it holds.
The draft legislation holds particular importance for multinational enterprises (MNEs) as it focuses on two crucial aspects of the GMT framework:
These provisions are designed to ensure that MNEs pay a minimum level of tax on their global income, irrespective of their jurisdiction of operation
The IIR, closely aligned with the OECD’s model rules and the accompanying commentary, obliges a qualifying MNE group to include a top-up amount in its income.
This amount is determined by evaluating the group’s effective tax rate against the stipulated minimum rate of 15%.
Notably, the draft legislation incorporates mechanisms for calculating this top-up amount, encompassing factors such as excess profits, substance-based income exclusions, and adjusted covered taxes.
The goal is to prevent instances where MNEs might be subject to lower tax rates in certain jurisdictions.
The QDMTT, on the other hand, allows jurisdictions to implement a domestic top-up tax to align with the principles of Pillar Two.
This is aimed at domestic entities within the scope of Pillar Two, counterbalancing the global minimum tax liability.
The intricacies of the QDMTT provision, including computations and adjustments, are outlined in the draft legislation to ensure an encompassing and fair application.
To effectively implement the Global Minimum Tax Act (GMTA), the draft legislation covers a spectrum of administrative facets.
These include provisions for assessments, appeals, enforcement, audit, collection, penalties, and other vital components to ensure the smooth functioning of the new tax regime.
As part of compliance measures, the legislation introduces the requirement of filing a GloBE information return (GIR) within 15 months of the fiscal year’s end, with potential penalties for non-compliance.
It’s important to note that the legislation doesn’t shy away from significant penalties for non-compliance.
Failure to file the required GIR within the stipulated timeframe could result in penalties of up to $1 million. Moreover, penalties may also be imposed as a percentage of taxes owed under the GMTA for not filing Part II or Part IV returns, adding a layer of urgency to adhere to these provisions.
One of the central themes that emerge from the draft legislation is the intricate interplay between the GMTA and Canada’s existing tax framework.
While the legislation attempts to bridge these two domains, certain aspects remain to be ironed out.
Notably, the interaction between the GMTA and provisions within the Income Tax Act (ITA) raises questions about the allocation of losses or tax attributions under the ITA to offset taxes owing under the GMTA.
Additionally, the draft legislation is deliberately silent on the specifics of this interaction, particularly concerning issues like Canadian foreign affiliate and foreign accrual property regimes.
As businesses and professionals delve into the consultation process, these areas of ambiguity are likely to be focal points of discussion, aiming to ensure a harmonious alignment between the new regime and the existing tax landscape.
The consultation process for the draft legislation is underway, with the Department of Finance welcoming feedback until September 29, 2023.
During this period, stakeholders, including businesses, tax professionals, and policymakers, have the opportunity to contribute insights and perspectives to shape the final legislation.
The complex and evolving nature of international taxation underscores the importance of robust consultation, as the new rules have far-reaching implications for cross-border businesses.
Canada’s proactive approach to aligning its tax laws with the global consensus on minimum taxation is a significant stride.
As the draft legislation undergoes scrutiny and refinement, it’s essential to recognize its implications not only for multinational enterprises but also for the broader tax landscape.
The interplay between the GMTA and the existing tax regime will be closely watched, highlighting the intricate path of international tax reform and the commitment of nations to creating a fair and balanced tax environment.
If you have any queries about this article on Canada and Global Minimum Tax, or Canadian tax matters in general, then please get in touch.
The content of this article is provided for educational and information purposes only. It is not intended, and should not be construed, as tax or legal advice. We recommend you seek formal tax and legal advice before taking, or refraining from, any action based on the contents of this article..
On July 19, the Portuguese Parliament took a significant step towards easing the country’s housing crisis by approving the ‘Mais Habitação’ (More Housing) legislative package.
This comprehensive set of measures aims to tackle the challenges of the housing market, and one notable change is the exclusion of real estate from the investment options available under the Golden Visa scheme.
Under the new legislation, the Portugal Golden Visa scheme will continue to be open for investment in other sectors as the government tests its viability without the property component.
However, the option to make a capital transfer of at least €1.5 million to Portugal has been withdrawn.
It’s important to note that these changes will not be applied retroactively, and existing rights of renewal for family reunification and permanent residency applications remain protected.
Non-EU nationals will still have several investment options available to them under the revised Golden Visa programme, including:
Eurico Brilhante Dias, the parliamentary leader for the ruling Socialist Party, explained that the government’s aim was to preserve a core of job creation and investment in Portuguese companies that already existed under the previous law.
The goal is to assess whether the Golden Visa scheme can thrive through investments in the productive sector, attracting foreign direct investment, and whether it can operate successfully without relying heavily on real estate investments.
The Golden Visa programme has been successful in attracting over €7 billion in investments from non-EU nationals since its inception in 2012. However, real estate investments have dominated, accounting for more than 90% of the total.
The new ‘Mais Habitação’ package seeks to diversify the investment landscape and reduce the dependency on real estate.
With the approval of the ‘Mais Habitação’ legislative package and the changes to the Golden Visa scheme, the Portuguese government aims to address the housing crisis and attract more diverse investments to the country.
As the focus shifts away from real estate, investors will have an array of options to explore when obtaining a Golden Visa and benefiting from Portuguese residence opportunities.
If you have any queries about this article on Portugal’s golden visa changes, or Portuguese tax matters more generally, then please do not hesitate to get in touch.
The content of this article is provided for educational and information purposes only. It is not intended, and should not be construed, as tax or legal advice. We recommend you seek formal tax and legal advice before taking, or refraining from, any action based on the contents of this article.
As Hungary continues its journey towards modernization, private clients must grapple with intricate tax considerations outlined in the Act of CXVII of 1995 on Personal Income Tax.
This is the main legislation dealing with personal income tax.
Like in many jurisdictions, determining tax residency in Hungary involves some care.
The following are likely to be resident for tax purposes in Hungary:
The definition extends to individuals with a permanent home, vital interests, or habitual abode in Hungary.
Hungarian tax residents are globally taxed, contrasting with non-residents taxed solely on income from Hungarian sources.
Hungarian-resident individuals face a 15% PIT rate on worldwide interest income.
PIT covers various scenarios, including publicly offered debt securities, where capital gains are deemed interest income.
To eliminate double taxation, Hungary provides tax credits or follows relevant double tax treaty rules.
Notably, interest income received in valuable assets triggers tax based on fair market value if withholding isn’t feasible.
Dividend income for Hungarian-resident private individuals is subject to a 15% PIT rate, along with a 13% social tax in 2023.
Distribution from entities in low-tax jurisdictions attracts additional taxes.
Capital gains, including those from the sale of shares, are subject to a 15% PIT rate and a 13% social tax in 2023.
Preferential PIT rules may apply to controlled capital market transactions.
Favorable tax treatment applies to qualified long-term investments, potentially leading to a zero percent tax rate after five years.
Hungary imposes an 18% tax rate on the net value of inherited or gifted properties.
Residential properties benefit from a preferential 9% rate.
Several exemptions exist, such as lineal relatives being exempt from tax, and exemptions for scientific, artistic, or educational purposes.
Transfer tax applies to real estate, movable property, rights of pecuniary value, and securities acquired through inheritance.
Shares in real estate holding companies may also incur real estate transfer tax.
Local municipalities may levy building tax, capped at 1,100 forints per square meter or 3.6% of the adjusted fair market value.
Land tax, imposed annually or based on adjusted fair market value, allows municipalities to charge up to 200 forints per square meter or a maximum of 3%.
Like their equivalents in other jurisdictions, private clients navigating Hungary’s tax landscape face a myriad of considerations.
Hopefully, our high level article underscores the importance of understanding the nuances to ensure compliance and optimize tax outcomes in this dynamic environment.
If you have any queries about this article on Hungary Private Client Tax Matters, or Hungarian tax matters in general, then please get in touch.
In a significant move, the Swiss electorate and cantons have voted in favor of implementing the Organisation for Economic Co-operation and Development (OECD) global minimum tax of 15% for large multinational enterprises operating in Switzerland.
This constitutional amendment was supported by an overwhelming majority, with 78.45% of voters and all cantons endorsing the proposal.
The implementation of the OECD minimum tax aims to safeguard Switzerland’s tax receipts and maintain its position as a stable business location.
The global minimum tax initiative has been developed by the OECD and the Group of 20 countries to establish a uniform minimum tax rate worldwide.
Under this framework, multinational companies with a global annual turnover exceeding €750 million will be subject to a minimum tax rate of 15% in each country they operate in.
Numerous countries, particularly in the European Union, plan to introduce the OECD minimum tax on 1 January 2024.
In Switzerland, 21 out of the 26 cantons currently have tax rates below the required 15%. Failure to meet the minimum tax rate would result in the imposition of a supplementary tax to make up the shortfall.
By implementing the minimum tax, Switzerland ensures that its tax receipts remain within the country rather than being shifted to other jurisdictions.
It’s important to note that the OECD minimum tax will only affect large multinational groups with an annual turnover of at least €750 million.
Small and medium-sized enterprises will not be affected by this amendment.
In Switzerland, approximately 200 internationally active groups headquartered in the country and 2,000 Swiss subsidiaries of foreign groups will be subject to the minimum tax.
As a result, around 99% of companies in Switzerland will continue to be taxed under the existing regulations.
The constitutional amendment to introduce the OECD minimum tax is in Switzerland’s best interest.
Without such a provision, jurisdictions in which Swiss multinational groups operate would be entitled to impose a subsequent tax to compensate for the difference in tax burdens, thereby impacting Switzerland’s tax revenues. Implementing the minimum tax rate ensures tax stability for Switzerland and provides legal certainty for companies affected by the new international tax rules.
However, it is worth considering the potential impact on tax competition within Switzerland.
High-tax cantons may become more attractive compared to those with lower taxes, as the introduction of the minimum tax limits the extent to which lower tax rates can be used to offset geographical disadvantages.
Switzerland’s embrace of the OECD global minimum tax represents a proactive step to secure tax revenues and maintain its status as an internationally stable business location.
By implementing the minimum tax, Switzerland ensures that tax receipts remain within the country and avoids the risk of revenue shifting to other jurisdictions.
While this decision may have implications for tax competition within Switzerland, the overall objective is to create a robust and equitable international tax framework.
The introduction of the OECD minimum tax paves the way for a more uniform global tax system, providing a level playing field for multinational enterprises across different countries.
If you have any queries about this article, or Swiss tax matters in general, then please get in touch.
The content of this article is provided for educational and information purposes only. It is not intended, and should not be construed, as tax or legal advice. We recommend you seek formal tax and legal advice before taking, or refraining from, any action based on the contents of this article.
Yesterday, Guernsey, Jersey, and the Isle of Man announced their intention to implement the OECD’s Pillar Two global minimum tax initiative.
The three Crown Dependencies have said that they will implement an “income inclusion rule” and a domestic minimum tax to ensure that large multinational enterprises (MNEs) pay a minimum effective tax rate of 15% from 2025.
Pillar Two is a new set of international tax rules that seek to address the problem of base erosion and profit shifting (BEPS).
BEPS is a practice by which MNEs use complex structures to shift profits to low-tax jurisdictions, thereby avoiding paying taxes in high-tax jurisdictions where the profits are generated.
The income inclusion rule is one of the two main components of Pillar Two. The income inclusion rule requires MNEs to pay a top-up tax in high-tax jurisdictions where their effective tax rate is below the 15% minimum.
The domestic minimum tax is the other main component of Pillar Two. The domestic minimum tax requires MNEs to pay a minimum tax in each jurisdiction where they operate, regardless of their effective tax rate.
The implementation of Pillar Two is a significant development in the global fight against BEPS. The rules are expected to raise billions of dollars in additional tax revenue for governments around the world. The rules are also expected to make it more difficult for MNEs to avoid paying taxes.
The announcement by Guernsey, Jersey, and the Isle of Man to implement Pillar Two is a positive development.
The three Crown Dependencies have a reputation for being tax-efficient jurisdictions. However, they have also been criticized for being used as tax havens by MNEs.
The implementation of Pillar Two will help to ensure that MNEs pay their fair share of taxes in the jurisdictions where they operate.
The implementation of Pillar Two will have a number of implications for MNEs. MNEs will need to review their global tax structures to ensure that they are compliant with the new rules.
MNEs may also need to increase their tax payments in high-tax jurisdictions.
The implementation of Pillar Two is a significant development for the global tax landscape. It will be interesting to see how MNEs respond to the new rules.
The rules will help to ensure that MNEs pay their fair share of taxes in the jurisdictions where they operate.
However, it is important to note that the rules are complex and will require careful implementation.
If you have any queries relating to the three Crown Dependencies’ implementation of Pillar Two, then please do not hesitate to get in touch.
The content of this article is provided for educational and information purposes only. It is not intended, and should not be construed, as tax or legal advice. We recommend you seek formal tax and legal advice before taking, or refraining from, any action based on the contents of this article.
The global wave of the two-pillar solution to address base erosion and profit shifting (which all the cool kids are calling BEPS 2.0) has reached Singapore.
Singapore will implement Pillar 2 of BEPS 2.0 in 2025, which will require multinational enterprises (MNEs) with local operations to top up their effective tax rate (ETR) in Singapore to 15%.
Many MNEs with Singapore operations currently benefit from tax incentives and enjoy an ETR lower than the upcoming 15%.
It is unclear whether existing incentives and exemptions will continue to apply, and whether Singapore’s territorial basis of taxation will change.
As the full effects of BEPS 2.0 are expected to be felt in 2025 or later, Singapore has chosen a cautious approach to delay implementation until then, giving itself time and a chance to learn from the experiences of other countries before determining the best way forward.
The implementation of Pillar 2 is crucial for Singapore, as it is an opportunity to increase revenue and fortify its fiscal position.
Under Pillar 1, Singapore is expected to lose revenue when profits are reallocated to the countries where markets are located. With a small domestic market, Singapore has to give up taxing rights to bigger markets and receives very little in return.
However, Pillar 2 presents a chance for Singapore to generate more corporate tax revenue, assuming that existing economic activities are retained.
The key to Singapore’s continued success is staying competitive in attracting and retaining investments.
The use of tax incentives may become obsolete or significantly compromised once the effects of BEPS 2.0 are felt.
Singapore has signaled that it will seek to reinvest and strengthen non-tax factors to remain competitive.
Whatever additional corporate tax revenue can be generated from BEPS 2.0 will be reinvested to maintain and enhance its competitiveness. Together with the intended implementation of Pillar 2, Singapore will also review and update its broader suite of industry development schemes.
The lack of details and the delayed implementation of Pillar 2 suggest that policymakers are looking for more information to guide their decisions. If there are additional delays internationally, it is likely that Singapore will adjust its implementation timeline.
Singapore has assured companies that it will continue to engage them and give them sufficient notice ahead of any changes to its tax rules or schemes.
MNEs that may be affected should actively participate in public consultation exercises before the implementation of Pillar 2 in 2025.
Those who currently benefit from an existing tax incentive should consider reaching out early to the relevant authorities if they are concerned about the implications of the new rules.
If you have any queries relating to the Singapore two pillar solution, or Singaporean tax matters more generally, then please do not hesitate to get in touch.
The content of this article is provided for educational and information purposes only. It is not intended, and should not be construed, as tax or legal advice. We recommend you seek formal tax and legal advice before taking, or refraining from, any action based on the contents of this article.
The UK’s Digital Services Tax (DST), which imposes a 2% tax on the revenues of search engines, social media platforms and online marketplaces, is set to be withdrawn as part of the Organisation for Economic Co-operation and Development’s (OECD) two-pillar plan to reform international corporate taxation.
The plan, announced on 1 July 2021, will see the UK commit to a 15% minimum level of global tax on large businesses under Pillar Two, in exchange for being able to tax a portion of the profits of the world’s largest businesses that are attributable to consumption in the UK under Pillar One.
The DST was introduced in 2020 as a temporary measure to address the challenges posed by the digital economy to international corporate taxation. The tax has been effective in raising £358m from large digital businesses in the 2020/21 tax year, 30% more than originally forecast.
However, the DST has faced significant international opposition, with the US arguing that digital services taxes unfairly target American firms and are discriminatory.
The compromise agreed with the US covers the interim period between January 2022 and either 31 December 2023 or the date Pillar One is implemented, whichever is earlier.
Under this compromise, the UK is able to keep its existing DSTs in place until the implementation of Pillar One, but US corporations subject to DSTs may receive tax credits against future tax liabilities.
As a compromise, the US has agreed to terminate proposed trade action and refrain from imposing any future trade actions against the UK.
The OECD’s two-pillar plan aims to reform international corporate taxation and make it fit for the digital age.
Pillar One will enable countries to tax a portion of the profits of the world’s largest businesses that are attributable to consumption in their jurisdictions, including the profits of the world’s largest digital businesses.
Pillar Two will introduce a global minimum tax rate of 15% on large businesses to prevent them from shifting profits to low-tax jurisdictions.
The UK has committed to ending its DST by the deadline of 31 December 2023 in order to adopt the OECD’s Pillar One model rules from 2024.
The UK government anticipates that it will introduce a domestic minimum tax in the UK to complement Pillar Two, likely to come into effect from 1 April 2024 at the earliest.
The withdrawal of the DST will have implications for digital companies operating in the UK. Businesses that have not yet been found liable for DST but consider that they may be in scope should revisit their DST exposure analysis.
The UK government’s commitment to introducing a domestic minimum tax may also have an impact on the tax liabilities of digital companies operating in the UK.
If you have any queries relating to UK Withdraws Digital Services Tax or tax matters in the UK more generally, then please do not hesitate to get in touch with a UK specalist Native!
The content of this article is provided for educational and information purposes only. It is not intended, and should not be construed, as tax or legal advice. We recommend you seek formal tax and legal advice before taking, or refraining from, any action based on the contents of this article.