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eCounsel group

A boutique firm with unparalleled expertise in business and technology. We have good command of industrial ecology and legal practice, and have undertaken highly regarded cases. Because the small business scope, we pay more emphasis on effectiveness and efficiency, and choose clients with deliberation. The managing partner not only has extensive experiences in various legal issues more over than 20 years, but invests and manages several technology companies. In addition, he always checks each case rigorously. Clients’ business objectives are our primary focus. To achieve the same in the most cost-effective fashion trumps all seemingly sophisticated legal discussions.

Those Who Have U.S. Citizenship, Beware of the Double Taxation Conventions

2014 - 11 - 03

FATCA is already disturbing, but very few people understand that the Double Taxation Conventions between Taiwan and U.S would be a thousand times worse.


FATCA足已令人擔憂,但很少人知道,台美租稅協議之害將千倍於FATCA。不論是綠卡或美國公民,萬一台美真的簽下去,勢必得準備脫產了。

脫產是可以做到完全符合台灣法令的,至於違不違反IRS的規定?這部份我們不予置評。

FATCA的本質,是由各國的「銀行」與美國政府訂契約,因此具有美國身分的銀行客戶,是可以選擇要不要對銀行誠實。銀行如果不知情,沒提供這部分的客戶資料給IRS,銀行沒差、客戶開心、美國政府無奈。

但是,政府間的租稅協議,和FATCA是天差地別的。執行上雖仍視其簽署之深度而定,但基本上,IRS把具有美國身分常往返台美的名單提供給台灣的國稅局、國稅局在比對之後把這樣的人在台灣的財產及所得(包括房地產、銀行帳戶餘額、名下持有之股票基金債券、車輛、薪資股利租金孳息等等)全部列表直接在個資已經全部曝光但台灣人民卻渾然不知的情形下送回IRS,是難度不算太高、只要資料庫的比對設計規劃完善,就能達成的目標。台美去簽租稅協定這件事情嚴重偏惠美國,難道政府不知道?

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