Years ago, I lived in Louisiana while working for Exon. Exon sent me to Okinawa for four years on company business. I had to pay U.S. taxes every year and didn't care about foreign taxation. I was an American working for an American company and that's all that mattered.
After 3 months of studying my exit: you’re the M A S T E R of International tax, I salute you 🫡 …you focussed me on Art 4 of double tax treaties….seems to be always art 4….. okay so I will have no house at permanent disposition and in the new country I will have that. Well: local tax law declares all breathing individuals or even aliens to be tax residents…. And the Int’l treaty trumps local law…. So: pls confirm: I don’t have to care about the secondary tie-brakers? (Local Economic interests)??? I assume that’s affirmative and jump out of the plane without further parachutes….. 😃👀
Yep the tie breake rules matter. Plenty of tax treaties can be bring you back into tax nets without proper physical residence. The most famous example is the US savings clause.
This is the biggest risk for the naive digital nomads. They are young and they are driven by dreams. Unfortunately tax is a nightmare instead. Probably the only way to not fall in the net is never get back living in your citizen country so that the tax authority of your citizen country can't have a grasp on you but still bit shady; or become worthless with no assets and income so no way for them to claim something. And remember coffins do not have pockets 😂so spend all your money before you die 😉
I checked the situation as a Swedish retiree moving to Florida permanently with zero connection to Sweden. In that case Sweden takes 25% of the Swedish pension, IRS nothing. And Florida has zero income tax.
@@FighterFred I found that property tax in NE FL 10 years ago was around 0.8% - 2% per year. You will pay FL property tax no matter who you are. Is there any state that doesn't have a property tax?
As I was challenging your video regarding digital nomads taxation as the info in my opinion were misleading. I can say that this one is a good one. Now this is my take and I would appreciate comments. If you are in a country like UAE where mostly you have zero taxes and your citizen country has a world wide taxation scope there will be zero interest that UAE tax authority will stand on your Tax Residence, in case of dispute with your own citizen country, because of the lack of interest. Your citizen country will definitely agress you on tax. Therefore unfortunately there is a big risk that you are triggering the last tie break rule and your tax optimization schema is going to be screwed up. You need to be really picky on building up your residence proof in a way that you are going to exclude falling in this trap. To make the story short either you are really living and having solid tight in the country you want to be tax resident or the outcome could be unexpected. Digital nomads citizens of countries with world wide taxation scope hardly can get away on that case.
Hello, Lopez! It doesn’t matter if tax authority of “whatever country” doesn’t have an interest to tax your worldwide income. It’s up to you to be sure you meet the criteria for becoming tax resident in that country. But, even if you are liable to taxation in that second country (even if 0%) , you need to provide to the first country the: tax residence certificate from the second country in order to go further to the “tax-breaker rule”!
@@AIRfree Of course I always get a tax residence certificate. The issue is when following the tie break rule both countries try to agree on who own the cake (which is one of the tie break rule befor the citizen one). No matter what I bet that the country that has 0% tax will not fight to claim the ownership of the tax residence and you will be screwed either because they can't agree and you will be reverted on your citizen either because there is no interest from the country with 0% tax to fight with the other country as nothing will flow in their Tax bucket (0%) ...
@@OffshoreCitizen thanks I will have a look on it. My major concern however is that for a digital nomad an agressive country will definitely challenge the stable/permanent residence and most probably will try to trigger the citizen rule
@@AIRfree I am not sure you are right, what I was trying to say is that despite you have a certificate residnecy in a favourable country like UAE a country like Italy may consider you still resdent in Italy and then trigger the rule of citizenship. Additionally if you are put in court from the Italian Tax Authority as a country like UAE is in the black list for residency there is the reverse duty for a defense to proof that you are resident in Italy. Normally is the accusation party that has the duty to proof you would be resident in Italy and not in UAE. Now as a digital nomad would be really hard to proof that you are stable living in UAE if you switch countries every 3 months.
Suggest you do not just wing it … it rambles , no one wants to know if it was grade 8, or 10 … write out the points you wish to make . Follow that script.
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Years ago, I lived in Louisiana while working for Exon. Exon sent me to Okinawa for four years on company business. I had to pay U.S. taxes every year and didn't care about foreign taxation. I was an American working for an American company and that's all that mattered.
FIRE .... brother ,,, you are fire ,,,, thankyou ,,,,, Caio bello
A pleasure!
How familiar are you with the topic?
After 3 months of studying my exit: you’re the M A S T E R of International tax, I salute you 🫡
…you focussed me on Art 4 of double tax treaties….seems to be always art 4….. okay so I will have no house at permanent disposition and in the new country I will have that.
Well: local tax law declares all breathing individuals or even aliens to be tax residents…. And the Int’l treaty trumps local law…. So: pls confirm: I don’t have to care about the secondary tie-brakers? (Local Economic interests)???
I assume that’s affirmative and jump out of the plane without further parachutes….. 😃👀
Yep the tie breake rules matter. Plenty of tax treaties can be bring you back into tax nets without proper physical residence.
The most famous example is the US savings clause.
This is the biggest risk for the naive digital nomads. They are young and they are driven by dreams. Unfortunately tax is a nightmare instead. Probably the only way to not fall in the net is never get back living in your citizen country so that the tax authority of your citizen country can't have a grasp on you but still bit shady; or become worthless with no assets and income so no way for them to claim something. And remember coffins do not have pockets 😂so spend all your money before you die 😉
You mean the slavery clause?
I checked the situation as a Swedish retiree moving to Florida permanently with zero connection to Sweden. In that case Sweden takes 25% of the Swedish pension, IRS nothing. And Florida has zero income tax.
Florida has no income tax but there's still the US Federal tax
@@OffshoreCitizen And property tax which is significant.
@@FighterFred I found that property tax in NE FL 10 years ago was around 0.8% - 2% per year. You will pay FL property tax no matter who you are. Is there any state that doesn't have a property tax?
What if the country you spend the most time in is one on which you spend 4 or 5 months, would you have to pay tax there?
Is it compulsory to file the form "Determination of residency status (entering Canada)" in order to declare deemed non resident?
Even if your tax residency don't have tax treaties, will you be fine if you respect all the rules?
Of course you're always fine if you follow all the rules. You just might pay a lot of tax
You are amazing ... wow .... just what I needed for accounting. Caio
Always happy to be of service :)
Anything else you'd like to see?
What about a country without a tax treaty? For example Panama if you were a tax resident there but do not have a permanent home in either country
Then you go to the next tie breaker
As I was challenging your video regarding digital nomads taxation as the info in my opinion were misleading. I can say that this one is a good one. Now this is my take and I would appreciate comments. If you are in a country like UAE where mostly you have zero taxes and your citizen country has a world wide taxation scope there will be zero interest that UAE tax authority will stand on your Tax Residence, in case of dispute with your own citizen country, because of the lack of interest. Your citizen country will definitely agress you on tax. Therefore unfortunately there is a big risk that you are triggering the last tie break rule and your tax optimization schema is going to be screwed up. You need to be really picky on building up your residence proof in a way that you are going to exclude falling in this trap. To make the story short either you are really living and having solid tight in the country you want to be tax resident or the outcome could be unexpected. Digital nomads citizens of countries with world wide taxation scope hardly can get away on that case.
Hello, Lopez! It doesn’t matter if tax authority of “whatever country” doesn’t have an interest to tax your worldwide income. It’s up to you to be sure you meet the criteria for becoming tax resident in that country. But, even if you are liable to taxation in that second country (even if 0%) , you need to provide to the first country the: tax residence certificate from the second country in order to go further to the “tax-breaker rule”!
@@AIRfree Of course I always get a tax residence certificate. The issue is when following the tie break rule both countries try to agree on who own the cake (which is one of the tie break rule befor the citizen one). No matter what I bet that the country that has 0% tax will not fight to claim the ownership of the tax residence and you will be screwed either because they can't agree and you will be reverted on your citizen either because there is no interest from the country with 0% tax to fight with the other country as nothing will flow in their Tax bucket (0%) ...
Please watch our videos on tax residency certificates (mostly not worth much) and The Tax Residency Myth, it addresses a lot of this
@@OffshoreCitizen thanks I will have a look on it. My major concern however is that for a digital nomad an agressive country will definitely challenge the stable/permanent residence and most probably will try to trigger the citizen rule
@@AIRfree I am not sure you are right, what I was trying to say is that despite you have a certificate residnecy in a favourable country like UAE a country like Italy may consider you still resdent in Italy and then trigger the rule of citizenship. Additionally if you are put in court from the Italian Tax Authority as a country like UAE is in the black list for residency there is the reverse duty for a defense to proof that you are resident in Italy. Normally is the accusation party that has the duty to proof you would be resident in Italy and not in UAE. Now as a digital nomad would be really hard to proof that you are stable living in UAE if you switch countries every 3 months.
How easy it is to trigger tax obligations accidentally?
Depends on whose the rules are
OUR PROBLEM IS GLOBALISM
Get to the f king point dude. Half way through and you’re still on Tokugawa period of Japan
Suggest you do not just wing it … it rambles , no one wants to know if it was grade 8, or 10 …
write out the points you wish to make . Follow that script.