Cross-border tax terms — D

The definitions here are unnumbered on purpose. A concept survives a budget; a threshold does not, and the two are easy to confuse once they sit in the same sentence.

Most of these terms exist because two tax systems describe the same thing differently, or because one system has a concept the other does not. That is where cross-border files go wrong quietly: a position that is obviously right at home has no counterpart abroad, and the mismatch — rather than the rate — becomes the exposure. So every entry is written in three parts: the meaning, the point at which it costs something, and the filings on this site that it governs.

If a term like this is in a notice you have received, bring the notice. The definition matters far less than what the sender is actually asking for. Every page here carries the name of the person who reviewed it and the date they did.

• Deemed resident — Someone treated as resident by a statutory rule rather than by ties.
• Dual-status alien — Someone who is a non-resident for part of a US tax year and a resident for the rest, usually in the year of arrival or departure.
• Domicile — A concept of permanent home used by several systems alongside residence.
• Deemed disposition — A rule that treats property as sold at market value even though nothing was sold — on emigration, on death, or on a change of use.
• Departure tax — The tax on the deemed disposition triggered when residency ends.
• Double taxation — The same income taxed twice.
• DTAA — Double taxation avoidance agreement — the term used in India for a tax treaty.
• Dual consolidated loss — A loss usable in two countries by the same economic group, restricted by rules designed to prevent it being deducted twice.
• DEMPE — Development, enhancement, maintenance, protection and exploitation — the functions that determine which entity is entitled to an intangible's return, regardless of legal ownership.
• Dependent agent — A person who habitually concludes contracts, or plays the principal role leading to them, on behalf of a foreign enterprise — creating a taxable presence without premises.
• Deemed dividend — An amount treated as a distribution although not declared as one — commonly a shareholder benefit, a loan or a secondary transfer-pricing adjustment.
• Deemed disposition on death — The rule treating most capital property as sold at market value immediately before death, which is how Canada taxes at death instead of levying an estate tax.
• Delinquent FBAR — A late account report filed with a reasonable-cause statement where the income was reported and no examination is under way.
• Distance selling — Cross-border sales to consumers, which trigger registration in the destination country once its own test is crossed.
• Day-count record — A contemporaneous record of presence by country.
• Departure valuation — Documentation of value on the day residence ended, which fixes the deemed disposition and is the figure most likely to be challenged.
• Dual citizenship — Holding two nationalities.

What the D entries have in common

17 terms begin with D. Follow the entry itself for the mechanism, the filings it decides, and the fixed fee attached to that work. Three to start with: Deemed resident, Dual-status alien and Domicile.

Nearby letters

C — 25 terms · E — 19 terms. The full A–Z lists all 297 terms in one place.

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