The Israeli Tax Authority (ITA) announced a new voluntary disclosure program (VDP or amnesty) for applications filed by taxpayers between December 12, 2017 and the end of 2019. The new program replaces an earlier program that stopped accepting applications at the end of 2016. The ITA reports that 7,549 applications were ...
December 19, 2017Leon Harris
OECD Deals Get Out of Jail Card On November 8, the OECD issued important guidance on how governments can catch tax evaders and, significantly, what rights taxpayers have. (“Fighting Tax Crime: The Ten Global Principles”). OECD guidance is back-door law in OECD member countries such as Israel. Article 6 of the OECD Convention, ...
December 13, 2017Leon Harris
בשנת 2018 ישראל עומדת לתקן את כל 56 אמנות המס שלה בבת אחת וזאת עקב חתימתה בתאריך 7.6.2017 על אמנה רב צדדית של ארגון ה - OECD על מנת ליישם הוראות הקשורות ל- Base Erosion and Profit Shifting) BEPS). BEPS הינה תכנית מקיפה של ארגון ה-OECD כנגד הזזת רווחים למקומות אופשור (offshore), ...
November 30, 2017Leon Harris
Israelis in hitech and other industries are often relocated to work abroad. At what time do they become foreign residents? For many years this was a mystery. The Israeli tax law says that dropping Israeli fiscal residency takes at least four tax years – two years in Israel under 183 ...
November 26, 2017Leon Harris
Israel has seen a wave of exit deals. Exits can be paid for with cash or shares of the acquirer, especially if the acquirer’s shares are publicly traded on a stock exchange – that is as good as cash isn’t it? Not if there is immediate tax to pay and ...
November 13, 2017Leon Harris
Are Bitcoins and Other Virtual Currencies Tax-Exempt? In 1964, the Dave Clark Five pop group raised room temperatures with their foot stomping hit “Bits and Pieces”. In 2017, the rise in bitcoin prices is again raising room temperatures. To add to the euphoria, some think there is a big Israeli tax loophole. With ...
October 25, 2017Leon Harris
Information Exchange Gathers Pace The first wave of automatic Common Reporting Standard (CRS) information exchanges has just begun between 49 countries. This is according to an OECD announcement on September 15. The 49 countries include Argentina, Barbados, Belgium, Bermuda, BVI, Cayman Islands, Cyprus, Czech Republic, Denmark, Estonia, France, Germany, Gibraltar, Greece, Guernsey, ...
October 24, 2017Leon Harris
Israel amends all 56 tax treaties In 2018, Israel’s 56 tax treaties may be amended in one go after signing on June 7, 2017 the OECD multilateral instrument (MLI) to implement tax treaty-related measures to prevent base erosion and profit shifting (BEPS). BEPS is the OECD program aimed at preventing offshore ...
October 24, 2017Leon Harris
President Trump and the Republican party issued a tax reform “framework” plan on September 27. It’s only 9 pages long so we don’t yet have full details and it has yet to be enacted. Given that, what’s in store for US businesses, US Olim, and everyone else? Business Taxation The framework proposes ...
October 4, 2017Leon Harris
In recent months we have witnessed several exit deals where Israeli hitech companies have been sold for a pretty penny. But suppose some of the consideration payable to the founders and key employees is held back and subject to staying on for a period as an employee in the post-acquisition group? Is ...
September 27, 2017Leon Harris