Overview
Simon Goldring, partner at law firm McDermott Will & Emery, said:
“In many ways, this makes sense for international clients, for example for the purposes of determining tax residence under domestic legislation where clients spend time in more than one jurisdiction. Many countries tie residence to day counts; with different tax years, it is easier to manipulate the tax residence rules in both jurisdictions to avoid residence. Also, to ensure relief from double taxation is not lost because the income concerned falls in different tax years.”