The Quinn Collapse


#1521

If she is tax resident in Ireland she would be obliged to declare the income from Russia and pay tax on it. She would be able to offset tax paid in Russia against taxes due in Ireland but even so there would be a substantial Irish tax bill as the withholding tax deducted in Russia would only have been 30% of the total.

On what are you basing your ‘Nope’? The only way that she wouldn’t be liable for tax on this as an Irish tax resident as I see it is if she had only just taken up tax residency and could pay on the remittance basis for the first year. But even then if the credit card spending was in Ireland then that would count as a remittance here I believe.


#1522

I could be wrong, but I thought the USA was the only country that required citizens to pay at least an equivalent tax rate as their home country. In other words, if Russian income tax was 25% and USA tax was 30% then a USA citizen in Russia would be required to send the 5% difference to the USA. I’m pretty sure that Ireland doesn’t have this requirement.


#1523

She was resident in Ireland at the time, not Russia. So she was primarily liable for Irish tax. The point is that if she paid some tax at source, she can offset that against her liability (depending on any dual taxation treaty with Russia – not sure if there is one?)

Also, the US does not necessarily require US citizens to pay tax on worldwide income. A US citizen living in Ireland, for example, pays no US tax on Irish income becasue of a dual taxation treaty between the countries (there is also an 80k foreign earned income deduction in case of no dual taxation treaty).


#1524

The US required its citizens to pay US tax on worldwide earnings even when they are not resident in the US for tax purposes.


#1525

No, see above.


#1526

This is all slightly tangental.

If this was income and she paid income tax in Russia she would still be liable for the balance of tax in Ireland if she was tax resident in Ireland.

I cant see the revenue accepting the explanations she gave in court as to where the money cane from and how it was distributed / spent.

Does she have a tax liability for this income, did she pay the tax (she must have a record of this), has she admitted tax evasion in the court?


#1527

You are correct re. Russia but re. the US case It’s not because of the dual taxation agreement (DTA); for the US citizen in Ireland the Irish rate is generally higher so the net tax due is generally zero. If you lived in Singapore you’d have to make up the difference. See below.

In the case of a Quinn resident in Ireland but with a salary in some random low tax country without a DTA then she could find herself paying, say 10% tax in the foreign country and then paying normal Irish tax without allowance for the tax paid. It wouldn’t surprise me if there are more random countries, companies and salaries to emerge.

irs.gov/publications/p54/ch0 … k100047580


#1528

Slasher – that applies where no dual taxation treaty exists only, AFAIK. For an Irish-resident US citizen, the treaty states that only Irish tax is payable regardless of the rate. There is no taxation treaty between the US and Singapore, hence the doc you linked would apply.


#1529

The existence of a tax treaty offsets the requirement, it doesn’t remove it. It is an allowed exception rather than being a right in itself.

edit: or what slasher said :smiley:


#1530

Did she declare the accounts to the Revenue.

She has clearly failed on the “keep proper accounts” front…


#1531

I don’t understand what you mean. It removes the obligation for US citizens to pay US income tax.


#1532

I would suspect that the Revenue are watching and waiting; Anglo are essentially extracting a lot of useful info that otherwise the Revenue would have to dig up themselves at great expense. Presumably once the Anglo cases are over, the Revenue can swoop in and simply re-use a lot of the testimony; they may have to get it again as evidence but they’ll know exactly where to look.


#1533

Ok I should have used Switzerland as an example! Thats not what DTAs are about.

For example: There is a dta with Switzerland, despite this my mate’s American missus and in laws have moved there and renounced their US , citizenship! Otherwise they’d be topping up their tax. My mate is English but has moved there too so he was explaining it to me

irs.gov/publications/p54/index.html
Publication 54 (2012), Tax Guide for U.S. Citizens and Resident Aliens Abroad

irs.gov/publications/p54/ch0 … k100047616
6. Tax Treaty Benefits


#1534

It derogates it - the underlying requirement remains, but the DTA is a layer on top that can come or go.


#1535

I’m really looking forward to Aoifes husband Stephen Kelly coming onto the stand and the questioning over the ‘incidental’ €50m worth of Russian Property he offloaded fairly rapid in 2011.

The Daily Mail has the story on those properties here > dailymail.co.uk/news/article … dders.html . I look forward to Stephen telling us he is not very good with numbers either. :smiley:


#1536

Another day in court and another Quinn who knows nuthin. :frowning:

irishtimes.com/newspaper/bre … ing28.html
independent.ie/breaking-news … 69538.html


#1537

It should be pretty easy to establish if there are limits to daily cash withdrawals using a credit card from a Bank of Ireland ATM. I thought it was 500 euro per day, but I may well be wrong. If a daily limit exists, it should be straight to the clink for her.

These people don’t merely hold the court in contempt, they hold us all in contempt.


#1538

Credit cards issued by Russian banks can override the daily withdrawal limits imposed by Irish banks. I’ve seen this first hand with one Russian bank (not Ocean Bank).


#1539

That’s useful information, thanks. You’d think that Ms. Quinn might have ventured such information to Justice Kelly when he queried her story, just to lend it a veneer of plausibility.


#1540

The claim is so specific:

independent.ie/national-news … 69519.html

One BoI ATM in Blanchardstown - could the wondrous powers of technology be employed to confirm that statement?