RicodJour a écrit profondement:
| > And Ball and Cipo are Entertainers par excellance
|
| And they contrast each other well. Cipo has always seemed light
| hearted (loan guarantees would help explain his current relaxed air)
| and you automatically like him, Ball is a guy you don't mind
| disliking. He is entertaining though. What's with the 'there is no
| malice here' comments Ball keeps spouting? It makes me think there's
| malice there.
The tax angle is tricky
Particularly so since Cipo is an Italian national and the Tax laws in
Italy are somewhat more complex than the average country.
The Anglophone countries, in fact most Common Law countries, are quite
simple in comparison and rely solely upon "Residence" (Note 1) as the
determining factor in whether taxes are exigible. Joint/Reciprocal Tax
Conventions/Treaties are (relatively) cut and dried there.
Domicile (Note 2) isn't really contemplated.
However, the Italians cooked up a "Domicilio Fiscale" or "Fiscal
Domicile" rule or status which Cipo walked Smack Bang into, which was
compounded by the fact that no substantial reciprocal
Convention/Treaty between Italy and Monaco exists since Monaco imposes
no Personal Income Tax. However in Italy if you are registered in your
Commune as "Residenza Anagrafica" they have you by the Short and
Curlies.
France has a somewhat similar setup, but does have a Joint
Treaty/Convention with Italy and Britain is somewhat more relaxed
still allowing the non-resident, even if a British Citizen, to visit
for less than 184 days per year without attracting tax, or an average
of 91 days per tax year over a four year period.
Cipo certainly had exceedingly poor advice, or as Davey is inclined to
think, blundered along on his lonesome hoping that he'd be OK since
Cipo hasn't been reported as instigating a damage action or
malpractice suit against any accountants or lawyers.
It would have been possible to achieve the Zero Tax Liability status
that Cipo thought he had, but it would have taken meticulous planning
and the professional fees would have been high.
But now he is faced with a big tax bill from the Italian Tax Leeches
and again, Davey feels that the burden could probably have been
lightened somewhat by negotiating with the Tax Authorities before they
issued the assessment notice, particularly the penalties and
interest impositions. It's not an uncommon practice, and Davey has
negotiated these down on several occasions. Again Cipo (presumably)
missed the boat.
But now he has to Ante Up. And Bankers, being [censored], don't like
lending to miscreants who have incurred the Wrath of the Tax Gods and
find themselves unable to pay. So he has to find the Roubles
somewhere. And Davey thinks Mickey Ball might have turned up Trumps
here.
The skill will be in avoiding tax on any loan/gift/third party payment
that he gets to settle the liability. (The interest on unpaid taxes is
unconscionably high, presumably to teach the Wankerz a lesson)
But there are legal ways of doing this and hopefully Cipo will have
now availed himself of one after getting competent accounting and
legal advice.
Note (1) Residence; Where one resides at any particular moment in time
Note (2) Domicile: The place to which, when absent, one always intends
to return
[SHAMELESS SELF PROMOTION: Should anyone need advice on related Tax
matters, Davey, although nominally retired for the last 20++ years,
still consults on International Taxation]
--
Davey Crockett
-
Driving a Stake through the
Heart of the Politically Correct
http://i247.photobucket.com/albums/gg146/sylviastolz/freesylvia.jpg
