news…Si e’ proprio cosi’ aprire una societa’ nel Delaware conviene ,la giurisdizione più economica presente in tutto il mondo dove costituire una società.
Particolarmente di notevole interesse soprattutto se non si intende fare trading, affari, negli Stati Uniti. Infatti, secondo la legge del Delaware non c’e’ nessuna imposta sugli utili a carico della società se questa soddisfa rispetta le seguenti condizioni:
-la società non svolge nessuna forma di business/attivita’ nel territorio statunitense e non deve avere conti correnti nel territorio ameriacano -i soci devono essere tutti stranieri residenti all’estero
-la società non possiede conti correnti bancari in U.S.A.
con questa fattibilita’ la LLC non paga nessuna imposta/tasse sugli utili conseguti fatta eccezione per una imposta unica a forfait di 200/250 dollari americani in forma annuale.
Altre utili indicazioni:
Numero minimo di soci è 1, senza distinzione nè di nazionalità nè di residenza.
Azioni sono nominative e non al portatore e i soci vanno indicati in fase di registrazione della società.
Anonimato, i soci (members) non compariranno in alcun elenco e registro ufficiale e saranno, difatto, anonimi. Gli azionisti non residenti sono esentati dalla tassa di ritenuta sui dividendi.
Solitamente queste società vengono costituite per eseguire operazioni in Europa.
Le Limited Liability Company per la loro elasticita’, e con una procedura semplice burocratica e soprattutto per l´anonimato che garantisce ai propri azionisti sono ideali per qualsiasi tipo di business nel campo dei servizi e prestazioni di ogni genere….consulenza, immobiliare, trust…
source: Offshore-Complete.com www.offshore-complete.com
duminică, 9 septembrie 2012
No vote, no tax - the Suffragettes and their tax protest
Drawing a straight line from the fussy and oppressive finery of late Victorian women’s fashion, to the racey, straight lines of the 1920s ‘flapper’ describes a surprisingly short period in history. In between these two incarnations of feminine style, stands the original ‘wild child’ of the early 20th century. Called ‘the Shrieking Sisterhood’, these hysterical suffragettes were mad, bad and dangerous to know. So much for historical stereotypes.
While some suffragettes chalked lines on pavements and wielded hammers and stones to smash windows in the streets, others were just as busy using hammers to barricade themselves in their homes. The lock-in became a means of protest against the obvious injustice of women being locked out of national politics. It is still profoundly shocking to realise that less than 100 years ago, it was illegal for women to take part in a British Parliamentary election. It was only in 1928 that women were finally granted voting rights equal to men.
Over twenty years before this, in 1906, the Liberals were swept into government by a landslide, helped in no small part by an army of women volunteer organisers. It was not until their second term in government, led by Asquith and Lloyd George, that the Liberals began to introduce a completely new system of taxation, including introducing National Insurance to try to provide some form of pension provision for ordinary workers. This provided the back-drop for one type of lesser-known protest, which aimed to pressure the government into granting votes to women.
Women householders were expected to pay their Imperial taxes, but were not considered full citizens of the state. The injustice was most obvious and often felt most keenly by wealthy, well-educated women landowners. Some of these voteless women were increasingly affronted by the fact that many of the male farm workers on their estates could vote, thanks to the electoral reform of the 1880s. The inconsistency of the situation was heightened by the fact that women householders had been granted municipal voting powers since 1869.
There were a few women tax resisters during the late Victorian period. It was not until the advent of a wider campaign for women’s suffrage, however, that the tax protest began to gain more momentum. It was perhaps afforded some legitimacy by an earlier campaign of ‘passive resistance’ to taxation conducted by Nonconformists against the Education Act of 1902. Thousands of church ministers and chapel-goers refused to pay church rates over an extended period. A few even went to prison over this matter of conscience. However, perhaps due to its sectarian nature, the protest failed to capture the public imagination or national headlines.
Given their association with the increasingly bitter struggle of the suffragettes, women tax resisters gained some notoriety, especially those whose protests ended in prison terms. The six week seige of Dora Montefiore’s home in 1906 London was widely reported at the time. Other tax resisters began to gather under the banner of the Women’s Tax Resistance League, formed in 1909. These women, many of them steeped in English history, drew their inspiration from a figure who at that time towered alongside Oliver Cromwell in the national consciousness: John Hampden. Hampden, an MP for the Aylesbury area, was seen as a Buckinghamshire hero for having refused to pay the ‘Ship Money’ of King Charles I. Several other Buckinghamshire people, including four women, also added their names to the initial protest.
It was this stand against what John Hampden saw as an unconstitutional tax, which drew Mrs Emmeline Pethwick-Lawrence to visit the Hampden monument at Chalgrove in 1910. Following the visit, the Women’s Social and Political Union also adopted tax resistance as one of its recognised means of protest. Their slogans included the war-cry of the American Rebels: ‘No taxation without representation’ and the more direct declaration: ‘NO VOTE, NO TAX’. Mrs Lawrence commented, "Just as John Hampden offered first passive resistance to authority and then active resistance, so the women had their course clearly marked out before them" (‘Votes for Women, Oct 7th 1910, p.4).
By July 1910 the WTRL boasted over 100 members, all of whom enlisted as being willing to take up this form of protest. However, a two-tier approach was adopted, which meant that some took action immediately, while others declared they were willing to become tax protesters once the total number of members reached 500. However, the total never exceeded 200 and even by 1911 there were still only 40 women actively making tax protests, according to Miss Raleigh of Uxbridge
Another was a resident of the town of Wendover in Buckinghamshire, Mrs Hamilton. Two years running, some of her goods were distrained and sold at the Red Lion pub in the centre of the town, where a meeting was then held to explain Mrs Hamilton’s reasons for resisting her Imperial taxes. Her arguments must have been persuasive for some. A local man, quoted in Mrs Hamilton’s Women’s Freedom League obituary, was reported to have said, "If ever there was a rebellion in the quiet village of Bucks, it was that day".
More impressive still was the Mrs Hamilton’s arguments seem to have won over the local tax collector himself, Mr Frederick Mead, who at a suffrage meeting in Aylesbury in November 1911, declared that he was in favour of women who had the municipal vote also gaining a vote for Parliament. Of course, his wife, who was active in hosting suffrage meetings herself, may have also played a part in persuading him!
The Women’s Tax Resistance League was particularly active in John Ha
mpden’s own county (the photo here shows the sign outside Saint Nicholas' church, in Great Kimble, close to Hampden's family roots) . In 1912 they organised a march to Aylesbury prison, to protest at the forced feeding of hunger-striking suffragettes held there. There were riotous scenes in the market square afterwards, with suffragette speakers being drowned out and roughly treated by elements in the crowd. Sylvia Pankhurst arrived to speak in the town the next day but suffragettes were refused permission for a public meeting by the town council.
Later that year, women tax resisters and their supporters were grudgingly allowed to lay a wreath at the unveiling of the statue of John Hampden in the market square. The wreath bore the names of the four original women tax resisters: Mrs Westall and Widows Bampton, Goodchild and Semple. The suffragettes reportedly handed out two thousand leaflets on the day and sold 200 copies of a booklet about John Hampden, written by Mrs Darent Harrison. Mrs Harrison was to be beseiged in her own home in Hastings the following year, after she refused to pay her taxes and also blocked attempts to have her goods distrained (see here).
Find out more about the suffrage protesters of Buckinghamshire, by pre-ordering the book: ‘Burning to get the Vote - The Women's Suffrage Movement in central Buckinghamshire (1904 - 1914)’. This is due for publication in 2013, to coincide with the 100th anniversary of the national Women’s Suffrage Pilgrimage. Pre-ordered copies attract a 20% discount (£12 compared to the RRP of £15). To pre-order copies, please send your name and address to colin@chesham4fairtrade.co.uk.
Click here for the link to the John Hampden Society website.
This blog is one of an occasional series about famous figures or events in the history of tax justice. Click here for a blog on Thomas Paine, and here for a blog about the 14th century 'Peasant's revolt' in England, which was brutally supressed by London's mayor.
While some suffragettes chalked lines on pavements and wielded hammers and stones to smash windows in the streets, others were just as busy using hammers to barricade themselves in their homes. The lock-in became a means of protest against the obvious injustice of women being locked out of national politics. It is still profoundly shocking to realise that less than 100 years ago, it was illegal for women to take part in a British Parliamentary election. It was only in 1928 that women were finally granted voting rights equal to men.
Over twenty years before this, in 1906, the Liberals were swept into government by a landslide, helped in no small part by an army of women volunteer organisers. It was not until their second term in government, led by Asquith and Lloyd George, that the Liberals began to introduce a completely new system of taxation, including introducing National Insurance to try to provide some form of pension provision for ordinary workers. This provided the back-drop for one type of lesser-known protest, which aimed to pressure the government into granting votes to women.
Women householders were expected to pay their Imperial taxes, but were not considered full citizens of the state. The injustice was most obvious and often felt most keenly by wealthy, well-educated women landowners. Some of these voteless women were increasingly affronted by the fact that many of the male farm workers on their estates could vote, thanks to the electoral reform of the 1880s. The inconsistency of the situation was heightened by the fact that women householders had been granted municipal voting powers since 1869.
There were a few women tax resisters during the late Victorian period. It was not until the advent of a wider campaign for women’s suffrage, however, that the tax protest began to gain more momentum. It was perhaps afforded some legitimacy by an earlier campaign of ‘passive resistance’ to taxation conducted by Nonconformists against the Education Act of 1902. Thousands of church ministers and chapel-goers refused to pay church rates over an extended period. A few even went to prison over this matter of conscience. However, perhaps due to its sectarian nature, the protest failed to capture the public imagination or national headlines.
Given their association with the increasingly bitter struggle of the suffragettes, women tax resisters gained some notoriety, especially those whose protests ended in prison terms. The six week seige of Dora Montefiore’s home in 1906 London was widely reported at the time. Other tax resisters began to gather under the banner of the Women’s Tax Resistance League, formed in 1909. These women, many of them steeped in English history, drew their inspiration from a figure who at that time towered alongside Oliver Cromwell in the national consciousness: John Hampden. Hampden, an MP for the Aylesbury area, was seen as a Buckinghamshire hero for having refused to pay the ‘Ship Money’ of King Charles I. Several other Buckinghamshire people, including four women, also added their names to the initial protest.
It was this stand against what John Hampden saw as an unconstitutional tax, which drew Mrs Emmeline Pethwick-Lawrence to visit the Hampden monument at Chalgrove in 1910. Following the visit, the Women’s Social and Political Union also adopted tax resistance as one of its recognised means of protest. Their slogans included the war-cry of the American Rebels: ‘No taxation without representation’ and the more direct declaration: ‘NO VOTE, NO TAX’. Mrs Lawrence commented, "Just as John Hampden offered first passive resistance to authority and then active resistance, so the women had their course clearly marked out before them" (‘Votes for Women, Oct 7th 1910, p.4).
By July 1910 the WTRL boasted over 100 members, all of whom enlisted as being willing to take up this form of protest. However, a two-tier approach was adopted, which meant that some took action immediately, while others declared they were willing to become tax protesters once the total number of members reached 500. However, the total never exceeded 200 and even by 1911 there were still only 40 women actively making tax protests, according to Miss Raleigh of Uxbridge
Another was a resident of the town of Wendover in Buckinghamshire, Mrs Hamilton. Two years running, some of her goods were distrained and sold at the Red Lion pub in the centre of the town, where a meeting was then held to explain Mrs Hamilton’s reasons for resisting her Imperial taxes. Her arguments must have been persuasive for some. A local man, quoted in Mrs Hamilton’s Women’s Freedom League obituary, was reported to have said, "If ever there was a rebellion in the quiet village of Bucks, it was that day".
More impressive still was the Mrs Hamilton’s arguments seem to have won over the local tax collector himself, Mr Frederick Mead, who at a suffrage meeting in Aylesbury in November 1911, declared that he was in favour of women who had the municipal vote also gaining a vote for Parliament. Of course, his wife, who was active in hosting suffrage meetings herself, may have also played a part in persuading him!
The Women’s Tax Resistance League was particularly active in John Ha
mpden’s own county (the photo here shows the sign outside Saint Nicholas' church, in Great Kimble, close to Hampden's family roots) . In 1912 they organised a march to Aylesbury prison, to protest at the forced feeding of hunger-striking suffragettes held there. There were riotous scenes in the market square afterwards, with suffragette speakers being drowned out and roughly treated by elements in the crowd. Sylvia Pankhurst arrived to speak in the town the next day but suffragettes were refused permission for a public meeting by the town council.Later that year, women tax resisters and their supporters were grudgingly allowed to lay a wreath at the unveiling of the statue of John Hampden in the market square. The wreath bore the names of the four original women tax resisters: Mrs Westall and Widows Bampton, Goodchild and Semple. The suffragettes reportedly handed out two thousand leaflets on the day and sold 200 copies of a booklet about John Hampden, written by Mrs Darent Harrison. Mrs Harrison was to be beseiged in her own home in Hastings the following year, after she refused to pay her taxes and also blocked attempts to have her goods distrained (see here).
Find out more about the suffrage protesters of Buckinghamshire, by pre-ordering the book: ‘Burning to get the Vote - The Women's Suffrage Movement in central Buckinghamshire (1904 - 1914)’. This is due for publication in 2013, to coincide with the 100th anniversary of the national Women’s Suffrage Pilgrimage. Pre-ordered copies attract a 20% discount (£12 compared to the RRP of £15). To pre-order copies, please send your name and address to colin@chesham4fairtrade.co.uk.
Click here for the link to the John Hampden Society website.
This blog is one of an occasional series about famous figures or events in the history of tax justice. Click here for a blog on Thomas Paine, and here for a blog about the 14th century 'Peasant's revolt' in England, which was brutally supressed by London's mayor.
Tax Treaties, DTAs
When a person or entity from one jurisdiction invests in another jurisdiction and earns income there, the question then arises as to which jurisdiction gets to tax which bits of the income. Countries sign Double Tax Treaties or Double Tax Agreements (DTAs) with each other that sort out these and other questions, and to prevent 'double taxation'. Three main questions stand out from a tax justice perspective. First, does the prevention of double taxation turn into double non-taxation? Second is the extent to which the jurisdiction that is the source of that income (i.e. the one that hosts the investment) gets to tax the income, as opposed to the jurisdiction where the investor is resident. A TJN briefing paper on source-based and residence-based taxation is here.
) A third is the extent to which treaties permit information exchange or transparency.
Apart from DTAs, there is another class of tax treaties that countries sign too: Tax Information Exchange Agreements (TIEAs). These are far narrower in scope and concern only the provision of information. Generally, countries prefer to sign TIEAs instead of DTAs with tax havens, for fear of fiscal leakage (see here for a briefing paper exploring the differences.) While our TJN information exchange page focuses most closely on TIEAs, this page focuses most closely on DTAs.
Double Tax Agreements tend to be based on two models: a dominant OECD model, on the one hand, and a model put forwards by the United Nations, on the other. In general, the OECD model gives greater emphasis to residence-based taxation - which is favourable to OECD countries, where many of the multinationals are residence. The UN model gives greater taxing rights to source jurisdictions, which are typically developing countries receiving inward investment. For a detailed technical comparison of the two, see Michael Lennard's Jan/Feb 2009 paper in the Asia-Pacific Tax Bulletin, The UN Model Tax Convention as Compared with the OECD Model Tax Convention – Current Points of Difference and Recent Developments, cited with the kind permission of IBFD. (For a less detailed assessment, see TJN's briefing paper on source- and residence-based taxation, linked above.) This 2008 paper The Purpose and Current Status of the United Nations Tax Work also by Lennard (and also with permission of IBFD) provides a shorter assessment of the differences between the OECD and UN models, along with some history.
Non-governmental organisations including TJN have raised concerns about the global tax treaty system and individual treaties. Questions have been raised as to whether DTAs may be constraining the policy space available to developing countries (and others) to implement pro-poor and progressive fiscal policies. Furthermore, in very many cases, DTAs do not provide an adequate basis for a fair and meaningful exchange of tax information between developing and developed countries, and in particular with secrecy jurisdictions. Furthermore, some argue that DTAs could be seen as a pretext: although they are supposed to prevent 'double taxation,' too often the result is double non-taxation - that is, the multinational can use treaties to escape, or largely escape, the tax net altogether. Literature and professional tax databases indicate that most governments home to multinational businesses do already provide for unilateral measures to avoid double taxation.
) A third is the extent to which treaties permit information exchange or transparency.Apart from DTAs, there is another class of tax treaties that countries sign too: Tax Information Exchange Agreements (TIEAs). These are far narrower in scope and concern only the provision of information. Generally, countries prefer to sign TIEAs instead of DTAs with tax havens, for fear of fiscal leakage (see here for a briefing paper exploring the differences.) While our TJN information exchange page focuses most closely on TIEAs, this page focuses most closely on DTAs.
Double Tax Agreements tend to be based on two models: a dominant OECD model, on the one hand, and a model put forwards by the United Nations, on the other. In general, the OECD model gives greater emphasis to residence-based taxation - which is favourable to OECD countries, where many of the multinationals are residence. The UN model gives greater taxing rights to source jurisdictions, which are typically developing countries receiving inward investment. For a detailed technical comparison of the two, see Michael Lennard's Jan/Feb 2009 paper in the Asia-Pacific Tax Bulletin, The UN Model Tax Convention as Compared with the OECD Model Tax Convention – Current Points of Difference and Recent Developments, cited with the kind permission of IBFD. (For a less detailed assessment, see TJN's briefing paper on source- and residence-based taxation, linked above.) This 2008 paper The Purpose and Current Status of the United Nations Tax Work also by Lennard (and also with permission of IBFD) provides a shorter assessment of the differences between the OECD and UN models, along with some history.
Non-governmental organisations including TJN have raised concerns about the global tax treaty system and individual treaties. Questions have been raised as to whether DTAs may be constraining the policy space available to developing countries (and others) to implement pro-poor and progressive fiscal policies. Furthermore, in very many cases, DTAs do not provide an adequate basis for a fair and meaningful exchange of tax information between developing and developed countries, and in particular with secrecy jurisdictions. Furthermore, some argue that DTAs could be seen as a pretext: although they are supposed to prevent 'double taxation,' too often the result is double non-taxation - that is, the multinational can use treaties to escape, or largely escape, the tax net altogether. Literature and professional tax databases indicate that most governments home to multinational businesses do already provide for unilateral measures to avoid double taxation.
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