Taxing Nomads

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Taxing Nomads

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Author : Reuven S. Avi-Yonah
language : en
Publisher:
Release Date : 2022

Taxing Nomads written by Reuven S. Avi-Yonah and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022 with categories.

The COVID pandemic and the rise of zooming has increased the ability of many people (primarily the rich) to work remotely. This in turn has led to more people moving to other countries to benefit from the ability to work remotely while enjoying other benefits such as lower housing prices, a more leisurely lifestyle, and in some cases greater political stability. Many Americans have used their newfound freedom to move overseas, e.g., to Italy. They and others like them are the new nomads. Such a move is not tax motivated because Italy has higher personal tax rates than the US. It does, however, raise interesting tax issues because the US (uniquely) imposes worldwide taxation on its citizens wherever they live, while Italy (like most countries) does not tax non-resident citizens but taxes its residents on worldwide income regardless of their citizenship status.The question is whether the US or the Italian regime is preferable in a world in which rich people can freely choose their residence jurisdiction regardless of their citizenship. Most of the literature (including my own) condemns the US approach as a historical anachronism and accepts the Italian approach as obvious. But this question requires reconsideration under changing conditions.The tax policy choice (whether a country should tax non-resident citizens or non-citizen residents on global income) raises issues that would have been very familiar to Erwin Seligman and his colleagues on the 1923 League of Nations report. A key issue in the US debate on adopting the Sixteenth Amendment (1913) to authorize an income tax was whether federal taxes should be based on the benefits provided to the taxpayer by the government (the benefits or exchange principle) or on the taxpayer's ability to pay taxes (the ability to pay principle). Seligman was a major advocate of the ability to pay principle, and of the consequent insistence that Congress has the power to tax all income “from whatever source derived,” since all income contributes to ability to pay. The ability to pay principle was also behind the adoption of the foreign tax credit and the rejection of exemption for foreign source income in 1918. The 1923 report is based on the benefits principle (“economic allegiance”), but the insistence that the residence jurisdiction must have the right to tax the income of its residents on a worldwide basis while allowing for credits for source-based taxes is derived from the ability to pay principle.Which principle is better suited for taxing nomads? In my opinion, it is the ability to pay principle and not the benefits principle. A US citizen living permanently abroad does not derive sufficient benefits from their US passport (and may in some cases not even have one and not be aware of her US citizenship if that resulted from being born in the US). But if taxation is based on ability to pay, the relevant ability to pay is that of adult members of a political community, who get to vote and thereby determine the appropriate tax rates and the degree of progressivity of the tax rate schedule. And since US citizens abroad can vote in US elections, they should be subject to US taxes based on their ability to pay, i.e., on global income from whatever source derived.Taxation of non-citizen residents, on the other hand, should be based on the benefits principle since they do not get to vote and therefore are not members of the political community in which they reside. Therefore, Italy should only tax US citizens residing in Italy on Italian source income, which reflects the benefits conferred on them by Italy, and not on foreign source income, which does not reflect such benefits. The US should credit those Italian benefits (source) based taxes in accordance with the priority of benefits (source) over ability to pay (residence) established by the 1923 report (the “first bite at the apple” rule).The problem with this proposal, of course, is that it encourages taxpayers to obtain passports in tax havens and live permanently in other countries, and if those residence countries will only tax them on domestic source income, the result is massive under-taxation of the rich. Such “non-dom” regimes are a serious problem under current rules because countries like the UK (and many others) have adopted them to attract the rich. But there are ways to address this issue since non-dom regimes are politically unpopular and therefore ripe for legislative change in democratic countries. First, a residence country should be able to impose tax on its residents on worldwide income if the country of citizenship does not do so at all. Second, while the country of citizenship should be able to impose any non-zero tax rate it wants on its citizens (that is the point of taxation based on voting in a democratic political community), that choice should be respected by the country of residence only if the citizenship is meaningful, i.e., if the resident non-citizen has real links to their country of citizenship and not just a nominal passport (under the well-established Nottebohm test adopted by the ICJ). Finally, the country of residence should respect the primacy of the country of citizenship only if its citizens (including non-resident citizens) are given a meaningful right to vote in free and democratic elections in the country of citizenship (as determined by outside observers).Hannah Arendt defined citizenship as “the right to have rights”. In today's deglobalizing world, citizenship has become more important than ever because an increasing number of people (refugees) are effectively stateless and do not have either diplomatic protection or the right of abode in their country of citizenship. In addition, the ability to work remotely has significantly increased the ability of the rich to move permanently to other countries without obtaining citizenship rights and obligations. In this context, I believe the US approach of taxing its citizens on global income regardless of where they live is justified by the ability to pay principle (but not by the benefits principle), and that the current practice of the US and most countries to tax non-citizen residents on global income is not justified (within the limits of the anti-avoidance rules outlined above). This may not be a drastic change from current rules for resident non-citizens because most of them do not have foreign source income. But for those that do (like the rich nomads of the pandemic), ability to pay (citizenship) is a better basis for taxation than benefits (residence). Seligman, I believe, would have approved.

Offshore Finance And Global Governance

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Author : William Vlcek
language : en
Publisher: Springer
Release Date : 2016-11-02

Offshore Finance And Global Governance written by William Vlcek and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-11-02 with Political Science categories.

This book analyzes shifting international taxation strategies in pursuit of tax nomads, individuals and companies who minimize their tax obligations among multiple countries. Focusing on the efforts of the United States, the collective endeavours of the European Union and the global initiative of the OECD under G20 guidance, it investigates their attempts to understand and control the mechanisms employed by such nomads. The author directs particular attention to intellectual property, used by multinational corporations to move income from high-tax to low-tax locations. Contrary to claims that globalization hinders tax collection, Vlcek argues that state sovereignty and state power remain the defining characteristic of international taxation. The EU and OECD in turn, he concludes, are leveraging cooperation with the US to force other countries to share taxpayer information with them. This significant work will interest economists, political scientists and tax experts. /div

Tax Planning For Fiscal Nomads Perpetual Travellers

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Author : Lee Hadnum
language : en
Publisher: CreateSpace
Release Date : 2014-01-15

Tax Planning For Fiscal Nomads Perpetual Travellers written by Lee Hadnum and has been published by CreateSpace this book supported file pdf, txt, epub, kindle and other format this book has been release on 2014-01-15 with Business & Economics categories.

Many people enjoy going on their summer holidays as a tourist in a foreign country. How would you fancy extending this 'holiday' permanently? It may not have been something you've previously thought of, but far from being a new or radical idea, there are many people who are already doing this, and depending on the nature of their investments, they are maintaining their capital and much of the returns on their investments without suffering taxes. These individuals are known by a variety of names including Fiscal Nomads, Perpetual Travellers and Cyber Gypsies. The basic principle is to exploit the residency rules in a number of countries so that you're not caught by any one country's tax net. Most people will do this by either travelling continuously or basing themselves in a handful of countries and only spending a few months in each. Providing care is taken as to the length of stay you could simply be treated as a tourist in each country and be exempted from any requirement to pay income tax. In this guide we look at how you can achieve this and the tax planning benefits and issues involved. Key issues covered include: Can you become a fiscal nomad? Do I need to establish residence overseas? Teleworking from home UK tax benefits for Fiscal Nomads Where to go? The top 2 residence schemes for Perpetual Travellers

Live Tax Free

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Author : Ken Fisher
language : en
Publisher: Tax-Free.Org
Release Date : 2021-10-11

Live Tax Free written by Ken Fisher and has been published by Tax-Free.Org this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-10-11 with categories.

Live Tax-Free is the definitive guide on how Americans can 'Live Better for less Abroad, ' including a more prosperous lifestyle, eliminate debt, spend less, and free up more money to invest.

There Must Be Fifty Ways To Tax A Digital Nomad

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Author : Marisa Ouro
language : en
Publisher:
Release Date : 2023

There Must Be Fifty Ways To Tax A Digital Nomad written by Marisa Ouro and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2023 with categories.

This paper considers the influence of taxation rules on digital nomads' choices to move from one country to another while being an employee. We analyse the constraints and incentives for this geographical freedom from three perspectives. The first two perspectives are Corporate Income Taxation (CIT), Personal Income Taxation (PIT), analysed under Portuguese domestic law and the OECD Model Convention (OECDMC). The third perspective is on the relationship between States, addressing both tax competition and cooperation between States. At the CIT level, we analyse the possibility of a digital nomad having a fixed place of business from where the enterprise develops all or part of its activity, creating a permanent establishment. Regarding this issue, we answer two questions more connected to digital nomads' lifestyles. The first is to know whether coworking spaces, hotels and Airbnb spaces can be considered a fixed place of business. The second one is whether the computer or smartphone of the digital nomad can be considered a fixed place of business. The answer to these dilemmas is not consensual and will always depend on a case-by-case analysis. Regarding the CIT topic, we also address the implications of the digital nomad constantly moving with the obligations under BEPS Action 13 and the possible implications under Pillar 2. Legal obligations derived from the CbCR require to indicate the number of employees allocated to a specific jurisdiction. Because of the implementation of Pillar 2 in the EU, it will be determinant to know in which jurisdiction an employee is carrying out activities for an MNE Group. At the PIT level, we analyse the issue from the perspective of the current wording of Articles 15 and 4 of the OECDMC, focusing on the amplification of taxation conflicts provided by the characteristics of digital nomads. Regarding the issue of tax competition, we address the so-called "digital nomads visas" and the influence of tax measures associated with it, stressing that this is not the sole factor influencing digital nomads' mobility. However, it has an actual weight on it. Concerning tax cooperation between States in the information exchange field, we point to the consequences deriving from the fact that the Common Reporting Standard is indiscriminate in scope and includes countries reported for human rights violating practices and with a high rate of corruption which may lead to people who have fled those countries and become digital nomads, seeing their foreign bank account details disclosed in those countries. In conclusion, the freedom of digital nomads to work remotely anywhere is always limited because their employer must assess the tax risks associated with such a move. Several States may also dispute their income, whether or not they are considered a tax resident there. At the same time, each State has its own 'siren song', with its tax attractions specially designed for remote workers. More than for any ordinary citizen, the tax issue will always have to be given much thought so that it can be a form of liberation rather than a prison of obligations wherever they go.

Mongol And Nomadic Taxation

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Author : John Masson Smith
language : en
Publisher:
Release Date : 1970

Mongol And Nomadic Taxation written by John Masson Smith and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1970 with Mongols categories.

Fiscal Federalism In Theory And Practice

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Author : Mrs.Teresa Ter-Minassian
language : en
Publisher: International Monetary Fund
Release Date : 1997-09-10

Fiscal Federalism In Theory And Practice written by Mrs.Teresa Ter-Minassian and has been published by International Monetary Fund this book supported file pdf, txt, epub, kindle and other format this book has been release on 1997-09-10 with Business & Economics categories.

Over the past few decades, a clear trend has emerged worldwide toward the devolution of spending and, to a lesser extent, revenue-raising responsibilities to state and local levels of government. One view is that the decentralization of spending responsibilities can entail substantial gains in terms of distributed equity and macroeconomic management. The papers in this volume, edited by Teresa Ter-Minassian, examine the validity of these views in light of theoretical considerations, as well as the experience of a number of countries.

Nomads And Soviet Rule

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Author : Alun Thomas
language : en
Publisher: Bloomsbury Publishing
Release Date : 2018-06-14

Nomads And Soviet Rule written by Alun Thomas and has been published by Bloomsbury Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018-06-14 with History categories.

The nomads of Central Asia were already well accustomed to life under the power of a distant capital when the Bolsheviks fomented revolution on the streets of Petrograd. Yet after the fall of the Tsar, the nature, ambition and potency of that power would change dramatically, ultimately resulting in the near eradication of Central Asian nomadism. Based on extensive primary source work in Almaty, Bishkek and Moscow, Nomads and Soviet Rule charts the development of this volatile and brutal relationship and challenges the often repeated view that events followed a linear path of gradually escalating violence. Rather than the sedentarisation campaign being an inevitability born of deep-rooted Marxist hatred of the nomadic lifestyle, Thomas demonstrates the Soviet state's treatment of nomads to be far more complex and pragmatic. He shows how Soviet policy was informed by both an anti-colonial spirit and an imperialist impulse, by nationalism as well as communism, and above all by a lethal self-confidence in the Communist Party's ability to transform the lives of nomads and harness the agricultural potential of their landscape. This is the first book to look closely at the period between the revolution and the collectivisation drive, and offers fresh insight into a little-known aspect of early Soviet history. In doing so, the book offers a path to refining conceptions of the broader history and dynamics of the Soviet project in this key period.

Nomads In The Middle East

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Author : Beatrice Forbes Manz
language : en
Publisher: Cambridge University Press
Release Date : 2021-12-02

Nomads In The Middle East written by Beatrice Forbes Manz and has been published by Cambridge University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2021-12-02 with History categories.

A history of pastoral nomads in the Islamic Middle East from the rise of Islam, through the middle periods when Mongols and Turks ruled most of the region, to the decline of nomadism in the twentieth century. Offering a vivid insight into the impact of nomads on the politics, culture, and ideology of the region, Beatrice Forbes Manz examines and challenges existing perceptions of these nomads, including the popular cyclical model of nomad-settled interaction developed by Ibn Khaldun. Looking at both the Arab Bedouin and the nomads from the Eurasian steppe, Manz demonstrates the significance of Bedouin and Turco-Mongolian contributions to cultural production and political ideology in the Middle East, and shows the central role played by pastoral nomads in war, trade, and state-building throughout history. Nomads provided horses and soldiers for war, the livestock and guidance which made long-distance trade possible, and animal products to provision the region's growing cities.

Nomads And Ottomans In Medieval Anatolia

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Author : Rudi Paul Lindner
language : en
Publisher: Routledge
Release Date : 2017-07-12

Nomads And Ottomans In Medieval Anatolia written by Rudi Paul Lindner and has been published by Routledge this book supported file pdf, txt, epub, kindle and other format this book has been release on 2017-07-12 with Social Science categories.

First published in 1997. Routledge is an imprint of Taylor & Francis, an informa company.