it seems extraordinary that McManus' team are claiming the benefits of the Ireland / US tax treaty when he has not been resident in Ireland for 20 years!!!
The musky aroma of sour grapes. I love it.Mr Gores [the loser of the backgammon match] withheld the $5.2 million on the money paid to Mr McManus on the basis that the winnings might be subject to US federal income tax.
I imagine that McManus' team find that life is extraordinarily rewarding.it seems extraordinary that McManus' team are claiming the benefits of the Ireland / US tax treaty when he has not been resident in Ireland for 20 years!!!
The domicile levy is payable by a person who is Irish domiciled and an Irish citizen. So he may have a case that the treaty applies to him. I can see why the Revenue and the IRS would not agree but don't think it is a straightforward case.
The mind boggles at the figures but it seems extraordinary that McManus' team are claiming the benefits of the Ireland / US tax treaty when he has not been resident in Ireland for 20 years!!!
He might have a case if the Irish Domicile Levy was a covered tax for the purpose of the Ireland/US treaty, but I don't see how it could be.
This is the dispute - is the domicile levy the same as income tax? The USC is considered to be part of income tax for the purposes of the double tax treaties.
For instance, would LPT be regarded as a covered tax?
From the article in the Sunday Business post the IRS sought to tax him as a non resident alien.
So I'm not clear if they are saying he is subject to tax in the States anyway! And that he could get a credit for the tax paid in the US, in Ireland on the basis of the DTA. But as he is not resident in Ireland that is of no use to him.
I assume that if he were resident here that his professional gambling income would be subject to Income Tax?
It appears to be the view of most articles that income can't be taxed in both countries which is not 100% true.
I'm not familiar with the US tax law but they seem to tax everything they can except Delaware companies!
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