Cross-border tax terms — J
2 terms beginning with J, each defined at mechanism level.
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What each entry gives you is the mechanism: the condition that triggers the term, and the consequence that follows. Amounts and rates belong on the filing pages, where they carry a tax year and a source.
A surprising share of cross-border trouble is translation rather than arithmetic. The same payment is employment income on one side and something else on the other, and nobody notices until two authorities have both assessed it. Each term page therefore says what the word means, why it bites, and which of our pages it actually changes.
Recognising a term like this in your own paperwork is the useful skill. Working out which side of it you fall on is a short call. Every page here carries the name of the person who reviewed it and the date they did.
- Juridical double taxation — The same person taxed on the same income by two states.
- Joint partner trust — A trust deferring the deemed disposition until the death of the surviving spouse, with the same cross-border caution as an alter ego trust.
Only one term begins with this letter. Its own page carries the full treatment; use the A–Z above for anything else.
Juridical double taxation and joint partner trust
The same person taxed on the same income by two states. This is what treaties are designed to relieve. Follow the entry itself for the mechanism, the filings it decides, and the fixed fee attached to that work.
Joint partner trust is the other entry under J. A trust deferring the deemed disposition until the death of the surviving spouse, with the same cross-border caution as an alter ego trust.
Nearby letters
I — 4 terms · L — 5 terms. The full A–Z lists all 297 terms in one place.
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What these engagements turn on
Treaty Relief Claimed on a Cross-Border Estate
The estate article can extend a proportionate credit where the two systems would otherwise both tax the same asset. Claiming it requires a valuation and a disclosure the estate may not expect to make.
Read how this one runsWithheld at the Statutory Rate When a Treaty Rate Applied
Where withholding has already gone out at the full domestic rate, the treaty rate is recovered rather than applied. The file establishes entitlement for each payment, then puts the documentation in place so the following year runs at the correct rate from the start.
Read how this one runsA Pension Taxed Where the Treaty Did Not Intend
Pension and annuity articles allocate taxing rights differently from employment income, and a flat withholding often exceeds what a return would produce. The alternative filing is elective and has a deadline.
Read how this one runsA Residency Determination Review After Leaving the Country
Residence is decided on ties, not on a form, and the review asks for evidence of every one of them. The file assembles the ties that were severed and the ones that remained, and answers the questionnaire against the treaty rather than around it.
Read how this one runsOne Salesperson Abroad, and a Corporate Filing Obligation
A single employee with authority to conclude contracts can create a taxable presence for the whole company. The review tests what the person actually does against the treaty article, and where a presence exists, works out what profit is attributable to it.
Read how this one runsTreaty Rate Refused Because the Paperwork Was Missing
A reduced rate under a treaty is available only where the payer is satisfied the recipient is resident in the treaty country. The certificate and the withholding form are what make the rate available at source instead of recoverable a year later.
Read how this one runsFifteen Per Cent Held Back From a Fee for Services in Canada
A payer must withhold from fees paid to a non-resident for services rendered in Canada, whether or not any tax is ultimately owed. A waiver applied for before the work is invoiced avoids the withholding; after it, the money comes back through a return.
Read how this one runsThe Local File That Has to Match the Accounts
A local file describes the entity's own controlled transactions and ties them to its statutory figures. Where the two do not reconcile, that is what an examiner opens with.
Read how this one runsAll case studies — every published engagement in one place.
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A partnership is taxed in the hands of its partners, so one engagement abroad can reach every partner's personal return. The order matters: the waiver is applied for before the invoice, the presence is tracked before it becomes an establishment, and the payroll is registered before the first day worked in the other country.
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